194105/EU XXVII. GP
Eingelangt am 26/07/24
Council of theEuropean Union
Brussels, 26 July 2024
(OR. en)12605/24
ADD 17

JAI 1253
FREMP 336
AG 148POLGEN 123
COVER NOTE
From:
date of receipt:
To:

Secretary-General of the European Commission, signed by Ms Martine
DEPREZ, Director
26 July 2024
Ms Thérèse BLANCHET, Secretary-General of the Council of theEuropean Union

No. Cion doc.:

SWD(2024) 817 final

Subject:

COMMISSION STAFF WORKING DOCUMENT 2024 Rule of Law
Report Country Chapter on the rule of law situation in Hungary
Accompanying the document COMMUNICATION FROM THE
COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL,
THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE
COMMITTEE OF THE REGIONS 2024 Rule of Law Report The rule oflaw situation in the European Union

Delegations will find attached document SWD(2024) 817 final.

Encl.: SWD(2024) 817 final

12605/24 ADD 17

GSC/mc
JAI.A
www.parlament.gv.at

EN

EUROPEAN
COMMISSION

Brussels, 24.7.2024
SWD(2024) 817 final

COMMISSION STAFF WORKING DOCUMENT
2024 Rule of Law ReportCountry Chapter on the rule of law situation in Hungary
Accompanying the document
COMMUNICATION FROM THE COMMISSION TO THE EUROPEANPARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIALCOMMITTEE AND THE COMMITTEE OF THE REGIONS
2024 Rule of Law Report
The rule of law situation in the European Union{COM(2024) 800 final} - {SWD(2024) 801 final} - {SWD(2024) 802 final} {SWD(2024) 803 final} - {SWD(2024) 804 final} - {SWD(2024) 805 final} {SWD(2024) 806 final} - {SWD(2024) 807 final} - {SWD(2024) 808 final} {SWD(2024) 809 final} - {SWD(2024) 810 final} - {SWD(2024) 811 final} {SWD(2024) 812 final} - {SWD(2024) 813 final} - {SWD(2024) 814 final} {SWD(2024) 815 final} - {SWD(2024) 816 final} - {SWD(2024) 818 final} {SWD(2024) 819 final} - {SWD(2024) 820 final} - {SWD(2024) 821 final} {SWD(2024) 822 final} - {SWD(2024) 823 final} - {SWD(2024) 824 final} {SWD(2024) 825 final} - {SWD(2024) 826 final} - {SWD(2024) 827 final} {SWD(2024) 828 final} - {SWD(2024) 829 final} - {SWD(2024) 830 final} {SWD(2024) 831 final}ENEN
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ABSTRACTThe 2023 judicial reform is being implemented. The National Judicial Council is exercising
its new competences to effectively counterbalance the powers of the President of the National
Office for the Judiciary. Rules on preliminary references to the Court of Justice of the EU
have been clarified, in line with the requirements of EU law. The transparency of caseallocation in the Kúria has further improved, yet concerns remain regarding the lack oftransparency of case allocation in lower courts. While the new legal framework aims at
limiting the risk of arbitrary decisions about the career of judges, no further steps were taken
to address concerns raised by the National Judicial Council. Political influence on theprosecution service remains, with the risk of undue interference with individual cases. The
freedom of expression of judges remains under pressure and smear campaigns against judges
continue in the media. The level of remuneration of judges and court staff has further
deteriorated. The efficiency of the judiciary in civil, commercial and administrative cases, aswell as the overall level of digitalisation of the justice system, remain high.
Hungary has adopted a new anti-corruption strategy for 2024-2025. Legislation on lobbying
and revolving doors is planned, while enforcement and oversight remain an issue as regards
asset declarations. The new Integrity Authority reports certain obstacles in fulfilling its
oversight tasks effectively, and the impact in practice of the Anti-Corruption Task Forceremains to be seen. Shortcomings regarding political party and campaign financing remain
unaddressed. Some high-level corruption cases have reached the indictment stage, but thelack of a robust track record of investigations of corruption allegations concerning high-level
officials and their immediate circle remains a serious concern. Court decisions reviewing
prosecutorial decisions not to investigate or prosecute corruption are still not binding andhave so far not brought significant results, although the possibility of judicial review
incentivises prosecutors to assess allegations more thoroughly. The suspension ofcommitments from EU funds under several EU programmes and the lack of disbursements
following a payment request under the Recovery and Resilience Plan persist, as no newmeasures have been adopted to remedy the outstanding rule of law and anti-corruption issues.
The threats to media pluralism highlighted in previous Rule of Law Reports have remained
unaddressed. No measures have been adopted or are planned to regulate the channelling ofstate advertising to media outlets, to guarantee the functional independence of the media
authority and to ensure the editorial and financial independence of public service media.
Journalists and independent media outlets continue to face numerous challenges including
seemingly coordinated smear and de-legitimisation campaigns, and selective access togovernment premises and events. Further legislative changes have introduced some
restrictions to freedom of information.
Increasing state interventions and arbitrary decisions of the authorities remain a problem forthe operation of businesses in the single market. The ‘state of danger’ has been further
extended until November 2024. The quality of law-making and the frequent changes inlegislation remain a significant cause for concern. The Constitutional Court still reviews the
merits of final rulings of ordinary courts in politically sensitive cases. Obstacles affecting
civil society organisations persist, while the new Protection of National Sovereignty Act
further undermines civic space. Concerns related to the State’s role in financing civil society
continue.

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RECOMMENDATIONS
Overall, concerning the recommendations in the 2023 Rule of Law Report, Hungary has
made:
x
x

x
x

x

x
x

No progress on improving the transparency of case allocation systems in lower-instancecourts, taking into account European standards on case allocation.
No progress on adopting comprehensive reforms on lobbying and revolving doors, andfurther improve the system of asset declarations, providing for effective oversight andenforcement.
No progress yet on establishing a robust track record of investigations, prosecutions andfinal judgments for high-level corruption cases.
No progress on introducing mechanisms to enhance the functional independence of themedia regulator taking into account European standards on the independence of media
regulators.
No progress on strengthening the rules and mechanisms to enhance the independent
governance and editorial independence of public service media taking into accountEuropean standards on public service media.
No progress on adopting legislation to ensure fair and transparent distribution ofadvertising expenditure by the state and state-owned companies.
No progress on fostering a safe and enabling civic space and remove obstacles affecting
civil society organisations, including by repealing legislation that hampers their capacityof working, in particular the immigration tax.

On this basis, and considering other developments that took place in the period of reference,in addition to recalling the obligation to comply with the rule of law-related rulings of the
ECJ and the rule of law-related infringement procedures referred to in the country chapter,the Commission’s assessment under the general regime of conditionality, the relevant
concerns raised in the Article 7(1) TEU procedure initiated by the European Parliament, therelevant commitments made under the Recovery and Resilience Plan, and the relevant
country-specific recommendations under the European Semester, it is recommended to
Hungary to:
x
x
x
x
x
x

Improve the transparency of case allocation systems in lower-instance courts, taking into
account European standards on case allocation.
Take structural measures to increase the remuneration of judges, prosecutors, and judicial
and prosecutorial staff, taking into account European standards on remuneration for thejustice system.
Adopt comprehensive reforms on lobbying and revolving doors, and further improve thesystem of asset declarations, providing for effective oversight and enforcement.
Establish a robust track record of investigations, prosecutions and final judgments forhigh-level corruption cases.
Introduce mechanisms to enhance the functional independence of the media regulatory
authority taking into account European standards on the independence of media
regulators.
Adopt legislation to ensure fair and transparent distribution of advertising expenditure by
the state and state-owned companies.

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x
x

Strengthen the rules and mechanisms to enhance the independent governance andeditorial independence of public service media taking into account European standards on
public service media.
Remove obstacles affecting civil society organisations and foster a safe and enabling civic
space, including by repealing legislation that hampers their capacity of working, inparticular the immigration tax.

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I.

JUSTICE SYSTEM1

Hungary has a four-tier ordinary court system. 114 district courts operate at first instance,
while 20 regional courts hear appeals from district courts and decide on certain cases at first
instance. Five regional appeal courts decide on appeals against decisions of the regional
courts. Administrative cases are dealt with by the ordinary courts (the Budapest Regional
Appeal Court hears appeals against first-instance decisions of the eight regional courts withan administrative department). The main role of the Supreme Court (Kúria) is to guarantee
the uniform application of the law. The Fundamental Law tasks the President of the National
Office for the Judiciary (NOJ), elected by Parliament, with the central administration of thecourts. The National Judicial Council is an independent body, with legal capacity andbudgetary autonomy acquired following the June 2023 reform, which supervises the NOJ
President and participates in the administration of the courts. Judges are appointed by the
President of the Republic following a recommendation of the NOJ President based on aranking of candidates established by the local judicial councils. The NOJ President cannot
deviate from this ranking without the prior consent of the National Judicial Council. In thecase of Kúria judges, the recommendation is made by the Kúria President. The Constitutional
Court is not part of the ordinary court system. The prosecution service is independent under
the Fundamental Law and is vested with powers to investigate and prosecute crime. The
Hungarian Bar Association and the regional bar associations are autonomous self-governing
public bodies.
Independence
The level of perceived judicial independence in Hungary is now average among both thegeneral public and companies. Overall, 41% of the general population and 40% ofcompanies perceive the level of independence of courts and judges to be ‘fairly or very good’in 20242. The perceived level of independence among the general public has increased incomparison with 2023 (35%), but it is lower than in 2020 (48%). The perceived judicial
independence among companies has increased since 2020 (26%), as well as in comparison
with 2023 (32%)3.
Following the legislative reform in 2023, the National Judicial Council exercises its newcompetences to effectively counterbalance the powers of the President of the National
Office for the Judiciary. As noted in the 2023 Rule of Law Report, Hungary adopted a
1

2

3

The assessments included in this country chapter do not prejudge any future assessment under Article 24 ofRegulation (EU) 2021/241 of the European Parliament and of the Council of 12 February 2021 establishing
the Recovery and Resilience Facility or under Article 15 of Regulation (EU) 2021/1060 of the European
Parliament and of the Council of 24 June 2021 laying down common provisions on the European Regional
Development Fund, the European Social Fund Plus, the Cohesion Fund, the Just Transition Fund and theEuropean Maritime, Fisheries and Aquaculture Fund and financial rules for those and for the Asylum,
Migration and Integration Fund, the Internal Security Fund and the Instrument for Financial Support for
Border Management and Visa Policy.
Figures 51 and 53, 2024 EU Justice Scoreboard, and Figures 50 and 52, 2022 EU Justice Scoreboard. The
level of perceived judicial independence is categorised as follows: very low (below 30% of respondents
perceive judicial independence as fairly good and very good); low (between 30-39%), average (between 4059%), high (between 60-75%), very high (above 75%).
45% of the companies are either fairly or very confident that their investments are protected by the law andcourts. Only 19% of the surveyed companies see the quality, efficiency or independence of justice as one of
the main reasons for concern about investment protection (Figures 55 and 56, 2024 EU Justice Scoreboard).

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legislative reform which establishes as of 1 June 2023 stronger powers for the National
Judicial Council. This reform was positively assessed by the Commission4. The Council has
started to exercise its new powers, taking a series of actions within its competence 5. For
instance, the Council has given binding opinions on numerous proposals of the NOJ President
to change the number of judicial posts in various courts or to second judges 6. The NOJ
cooperated with the Council to support its institution building; after the end of the 9-month‘incubation period’7, since 1 March 2024, the National Judicial Council has been able to fully
exercise its budgetary autonomy8. The newly elected 14 judges-members – including one
regional court president9 – took office on 30 January 2024. On 14 February 2024, the Council
set up an ad hoc committee to analyse the last election process and make recommendations
for possible changes to the legislative framework10.

4

5

6

7

8

9

10

The reform aimed at addressing the justice-related milestones of Hungary’s RRP. It also relates to thehorizontal enabling condition on the EU Charter of Fundamental Rights, as regards to judicial independence.
On 13 December 2023, in the context of the Common Provisions Regulation, the Commission adopted adecision considering that Hungary had taken the necessary measures for the Commission to consider that thehorizontal enabling condition on the Charter as regards judicial independence is now fulfilled. The European
Parliament has challenged this decision before the Court of Justice (case C-225/24, pending).
On 7 June 2023, the Council elected its first (non-rotating) president and vice-president; made a legislative
proposal – supported by the Kúria President, the NOJ President and the Hungarian Association of Judges –to the Minister of Justice related to judicial salaries; adopted its own budget; and requested the NOJ
President to grant access to a classified report containing the results of an enquiry into the failure of the
President of the Budapest Regional Court to shield a senior judge from undue external pressure. On 6
September 2023, the Council gave consent to the 2024 training schedule for judges. On 4 October 2023, theCouncil determined the structure of the NOJ President’s biannual report. On 8 November 2023, the Council
gave consent to the decision of the NOJ President related to the rules on the end-of-the-year bonuses payable
to judges. On 6 December 2023, the Council invited the Minister of Justice to review the Decree setting out
the point system applicable to the evaluation of applications for judicial posts. On 27 March 2024, theCouncil gave binding opinions as regards the suitability of candidates for the post of Kúria Vice President.
On 17 April 2024, the Council gave binding opinions as regards the suitability of candidates for the post of
NOJ Vice President.
The Council has several times refused to give consent where it found that the NOJ President’s proposal
lacked sufficient explanations (contribution from Res Iudicata Association for the 2024 Rule of Law Report,
p. 11). The Council did not agree (Decision 89/2023 of 4 October 2023) with the secondment (‘beosztás’) asof 1 October 2023 to the Ministry of Foreign Affairs of a former member of the Constitutional Court who
had been appointed to the Budapest Regional Appeal Court as of 2 September 2023 following his request,
after becoming a judge in 2020 outside the ordinary appointment procedure.
For a period of nine months, the NOJ provided administrative support to the National Judicial Council which
gained legal capacity and budgetary autonomy and had to build adequate administrative capacity. The
Council accepted its first elected president’s report also covering the Council’s institution-building efforts inthe period 7 June 2023 to 30 January 2024 (Decision 34/2024 of 13 March 2024). The Council’s institution
building continued following the ‘incubation period’ (verbatim minutes of the 27 March 2024 meeting of the
National Judicial Council).
Information received in the context of the country visit to Hungary from the National Judicial Council andthe National Office for the Judiciary.
Stakeholders expressed concerns as regards the possibility for court presidents, appointed by the NOJ
President, to become members of the National Judicial Council tasked with supervising the NOJ President(contribution from Res Iudicata Association for the 2024 Rule of Law Report, p. 13; contribution from
Magistrats Européens pour la Démocratie et Libertés (MEDEL) for the 2024 Rule of Law Report, p. 14).
Pursuant to the 2023 reform, court presidents and vice-presidents are no longer allowed to participate in the
deliberation and vote on matters relating to their administrative activities.
Verbatim minutes of the 14 February 2024 meeting of the National Judicial Council. The President of theCouncil explained that the experiences of the last elections need to be analysed based on an overview of theway how the procedure was conducted in the different courts. The ad hoc committee was also tasked with5

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The transparency of case allocation in the Kúria has improved as a result of the 2023
reform. The Kúria President amended11 the case allocation scheme as of 16 July 2023 tobring it in line with the requirements of the legislative reform12 applicable as of 1 June 2023.
In January and April 2024, the case allocation scheme was further amended. It now contains
clearer rules on forming three- and five-judge panels where the number of judges assigned tothe chamber exceeds five or when the number of presiding judges assigned to the chamber
exceeds two13. Special rules applied to the composition of three-judge panels hearing cases
related to the 2024 European parliamentary and municipal elections14. As of 6 February 2024,
following the entry into force of a Ministerial Decree15, the Kúria extended the data content
of the log files published weekly on its web site, which allow anyone to verify more easily
whether the rules on case allocation have been duly applied. While also reorganising two
Chambers of the Civil Department, the Kúria President dissolved, as of 1 January 2024,
Chamber II of the Administrative Department and its judges were assigned to otherchambers16. The Kúria explained this decision as motivated by staffing reasons17, howeverstakeholders described it as arbitrary18.

11

12

13
14

15

16

17

making proposals for a possible change to the applicable law and internal regulations, where necessary.
Substitute members were elected on 15 January 2024. Former members of the Council decided not to run for
office. The National Judicial Council is composed of the Kúria President ex officio and 14 judges-members(and 14 substitute members) elected by their peers for a period of six years. Judges-members (one court ofappeal judge, six regional court judges and seven district court judges) are elected by a conference ofdelegates from among delegate judges. The full court of the Kúria and the plenary sessions of each of thefive regional appeal courts and the 20 regional courts elect 2 to 20 delegates.
In line with Sections 9(1), 151(2) and 155(2) of Act CLXI of 2011, as amended by Act X of 2023, theamendment to the case allocation scheme was issued by the Kúria President with the consent of the Kúria’s
three departments (‘kollégium’) and judicial council (input from Hungary for the 2024 Rule of Law Report,
p. 2; contribution from the Kúria for the 2024 Rule of Law Report, p. 1).
Act X of 2023. See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, pp.
5-6.
Contribution from the Kúria for the 2024 Rule of Law Report, p. 1.
Currently, the Kúria’s Administrative Department has seven chambers (one of them only dealing with thereview of municipal decrees) composed of at least two presiding judges and at least three other judges.
Election-related cases are heard by three-judge panels (Section 229(2) of Act XXXVI of 2023 on electoral
procedure). Under the current rules, three-judge panels are composed of two presiding judges of the chamberand one other judge assigned to the chamber.
Decree 18/2023 of 7 December 2023 of the Minister of Justice amended Decree 14/2002 of 1 August 2002of the Minister of Justice laying down the rules on judicial case management. On 13 December 2023, theCommission positively assessed this legislative amendment under Article 15 of the Common Provisions
Regulation. The amendment clarifies that the Kúria shall enter into the register (‘lajstrom’) corresponding to
the case category (‘ügycsoport’) all ‘initial documents’ (‘kezdőirat’) received by electronic means in theorder of receipt, under the next registration number, with the proviso that as for the registration of the cases,
each case shall be assigned a case number in an automated manner, without human intervention. Hungary
has committed to take the necessary actions to ensure that an external forensic expert, independent from the
Kúria, the NOJ and the Government, will conduct an audit by 30 June 2024 with regard to the compliancewith this new rule and that the European Commission will have access to the audit report. On 28 June 2024,
a report by a forensic expert was delivered. Also, the amendment specifies the data content of the weekly log
files that the Kúria publishes on its website, in accordance with Section 10(7) of Act CLXI of 2011. These
logs now also show the date and time of arrival, registration and allocation of cases and the composition of
the bench.
The number of judges assigned to these chambers now exceeds five (five judges sit on a panel hearing an
administrative case). The ongoing cases heard by Chamber II were reassigned to other chambers.
According to the Kúria, the change in the organisation of the Administrative Department was entirely basedon objective circumstances, with the retirement of one head of panel and one judge in January and March
2024, respectively (written contribution from the Kúria in the context of the country visit to Hungary).

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Rules on preliminary references to the Court of Justice of the EU have been clarified, inline with the requirements of EU law. On 12 December 2023, Parliament adopted a law19
amending the Criminal Procedure Code to remove any doubt as regards the right of judges torequest in criminal proceedings a preliminary ruling from the Court of Justice in relation to
any EU legal act or legislation20. At the same time, concerns have been raised as regards thenational preliminary reference procedure before the Kúria in the interest of uniformity oflaw21. The Court of Justice confirmed in a preliminary reference from a Hungarian court thatany court must be able to disregard the legal assessment of a higher national court if itconsiders, having regard to the interpretation of EU law provided by the Court of Justice, thatsuch assessment does not comply with EU law22.
There has been no progress to address concerns regarding the lack of transparency ofcase allocation in lower courts. The 2023 Rule of Law Report recommended to Hungary to‘[i]mprove the transparency of case allocation systems in lower-instance courts, taking into
account European standards on case allocation’23. In accordance with the applicable
Hungarian legislation, these case allocation schemes continue to be established and regularly

18

19

20
21

22

23

According to the Government, the measure can be explained by the introduction of five-judge panels (a 20%
decrease in the number of cases and, as a result, the unreasonableness of filling vacant positions).
Stakeholders indicated that Chamber II had handed down decisions unfavourable for the Government inpolitically sensitive cases; information received in the context of the country visit to Hungary from the
National Judicial Council, Hungarian Association of Judges and Eötvös Károly Policy Institute. See also
Kovács, Ágnes (2023): Taking Revenge for Dissent: Hungary’s Chief Justice to Fully Eliminate Judicial
Autonomy, VerfBlog.
Section 35 of Act LXXXV of 2023 amending certain Acts required for strengthening the interconnectednessof universities, research institutes and the economy and certain Acts in the field of vocational training andculture entered into force on 13 February 2024. On 13 December 2023, the Commission positively assessed
this legislative amendment under Article 15 of the Common Provisions Regulation.
Section 490, paragraph (1), of the Criminal Procedure Code.
The preliminary reference procedure in the interest of uniformity of law can be applied in two scenarios: (i)when a Kúria chamber wishes to deviate from the Kúria’s published case-law, it must stay the proceedings
and request a uniformity decision; (ii) the Kúria (Vice) President, the heads of Kúria departments and theProsecutor General may request a uniformity decision if it is necessary to ensure the uniform interpretationof the law, or to alter or annul a previous uniformity decision, also if this question does not arise in a
concrete pending case. The Kúria’s uniformity decisions are binding on the courts until the uniformity
complaint panel changes the decision.. By contrast, other published decisions of the Kúria act as a limited
precedent: since 1 April 2020, lower-level courts have been required by law to explain why they do notfollow the interpretation of legal provisions given by the Kúria in its published decisions. Such deviation is aground for an extraordinary remedy before the Kúria. Deviation by a Kúria chamber from the Kúria’s
published case law requires a new decision of the Kúria’s uniformity complaint panel. Preliminaryreferences in the interest of uniformity of law are heard by the uniformity complaint panels composed of the
Kúria President and Vice President and 20 senior judges (the Secretary General, heads and deputy heads ofdepartment and presiding judges).
In January 2024, the Court of Justice ruled that the principle of the primacy of EU law must be interpreted as
requiring the national court, having exercised the power conferred on it by Article 267 TFEU, to disregard
the legal assessments of a higher national court if the referring court considers, having regard to theinterpretation of a provision of EU law provided by the Court of Justice, that those assessments do notcomply with EU law; that principle does not, however, preclude national legislation which merely requires
lower national courts to give reasons for any departure from those assessments (judgment of the Court ofJustice of 11 January 2024, Global Ink Trade Kft., C-537/22, ECLI:EU:C:2024:6, para. 30). On 15 January2024, the Kúria issued a press statement clarifying that the cited judgment of the Court of Justice does notaffect the obligation of Kúria chambers to request a uniformity decision that is capable of removing thebinding effect of the Kúria’s published case-law which is no longer compatible with EU law.
2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2.

7

www.parlament.gv.atamended by court presidents. Judicial councils have no meaningful role in the process andparties to court proceedings cannot verify the proper application of the schemes or whether
there was a derogation from them24. The applicable rules have not been amended and there
are no plans yet to do so25. Therefore, there has been no progress on the recommendation
made in the 2023 Rule of Law Report.
While the new legal framework aims at limiting the risk of arbitrary decisions about the
career of judges, no further steps were taken to address concerns raised by the National
Judicial Council. In July and September 2023, the National Judicial Council found that in
2022 the NOJ President and the Kúria President had respected applicable rules when
appointing judges to the bench26. There are however no legislative plans to address theconcerns expressed by the National Judicial Council as regards the practice of the appointing
authority when deciding in a single batch on multiple applications for multiple judicial
posts27. In the National Anti-Corruption Strategy, the Government called on the Minister ofJustice to review the current point system applicable to the evaluation of applications forjudicial posts, which stakeholders consider to favour candidates coming from public
administration over candidates from within the judiciary28. No follow-up has been given to
the draft legislative proposal prepared by the NOJ President to amend the rules related to theassessment of the suitability for judicial tenure of judges appointed for an initial three-year
period. This proposal would move forward their evaluation in view of a proposal for judicial
tenure, thereby allowing for any judicial review of their evaluation to be completed before theend of their fixed-term appointment29. When recommending the appointment of the Kúria
24

25

26
27

28

29

2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 6. According tostakeholders there is still too much room for deviation from the general rules on case allocation (contribution
from Eötvös Károly Policy Institute for the 2024 Rule of Law Report, p. 15; information received in thecontext of the country visit to Hungary from the National Judicial Council) and court presidents can freely
reshuffle or dissolve chambers of judges (joint contribution from Amnesty International Hungary and eight
other CSOs for the 2024 Rule of Law Report, p. 11).
Input from Hungary for the 2024 Rule of Law Report, p. 3. According to the Government, a pre-definedsystem for the allocation of cases ensures that the allocation of cases is independent from the court
executives’ ad hoc or subjective decision. Based on such system, both the judges and the clients can establish
why a case was assigned to a specific judge/panel. According to stakeholders, the new rules on caseallocation applicable to the Kúria could be applied to other courts as well (information received in thecontext of the country visit to Hungary from the Hungarian Association of Judges).
Decisions 64/2023 of 5 July 2023 and 81/2023 of 7 September 2023, respectively.
According to stakeholders, in the absence of legislative amendments, this loophole allows the circumventionof the merit-based appointment system (contribution from European Association of Judges for the 2024 Ruleof Law Report, p. 6; contribution from Eötvös Károly Policy Institute for the 2024 Rule of Law Report, p.
11). See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 4.
Stakeholders pointed out that in the absence of legislative amendments, this loophole is still available tocircumvent the Council’s right to veto and undermine the meritocratic appointment system (information
received in the context of the country visit to Hungary from Hungarian Helsinki Committee). The
Government has no plans to propose legislative amendments in that respect (written contribution from theauthorities in the context of the country visit to Hungary).
Contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law Report, p.
4; contribution from Eötvös Károly Policy Institute for the 2024 Rule of Law Report, p. 11; information
received in the context of the country visit to Hungary from the Hungarian Association of Judges. The
National Judicial Council adopted a detailed proposal to change the point system (Decision 125/2023 of 6
December 2023). The Ministry of Justice has no plans to review the point system (written contribution fromthe authorities in the context of the country visit to Hungary).
The draft legislative proposal does not include provisions preventing the interruption of the judicial career
during the review of the evaluation, raising some concerns as regards effective judicial protection of the8

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Vice Presidents, the Kúria President is not bound by the ranking established by the full court,
while the National Judicial Council gives a binding opinion as to the suitability of thecandidates. On 13 June 2024, the Council of Europe’s Committee of Ministers reiterated its
request to the Hungarian authorities to step up their efforts to find ways to introduce therequired measures to ensure that a decision to remove the President of the Kúria is subjectedto effective oversight by an independent judicial body30.
The freedom of expression of judges remains under pressure. Smear campaigns against
judges continue in the media31. Also, the February 2024 decision of the Kúria President tosuspend the publication of the Kúria’s official court reports was criticized by stakeholders32.
As regards the effect of the violations in the Baka case33 on the freedom of judges to express
their views on matters of public interest concerning the judiciary, on 13 June 2024, theCouncil of Europe’s Committee of Ministers reiterated serious concern that the Hungarianauthorities had not produced their announced evaluation of the domestic legislation on thestatus of judges and the administration of courts34.
The structure of the prosecution service remains unchanged and risks of undue
interference with individual cases remain. The 2023 and previous Rule of Law Reports
noted that the strictly hierarchical architecture of the prosecution service and a lack ofinternal checks and balances enhance the persistent risk of top prosecutors influencing thework of subordinate prosecutors, including in individual cases35. Hungary has not
implemented GRECO’s recommendation to review the possibility to maintain the Prosecutor
General in office after the expiry of his/her mandate by a minority blocking of the election in
Parliament of a successor36. A new law37 will allow the Minister of Justice to access the

30

31

32

33

34
35

36
37

judges concerned. See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p.
5.
CM/Del/Dec(2024)1501/H46-15. See also 2023 Rule of Law Report, Country Chapter on the rule of law
situation in Hungary, p. 7.
On 7 July 2023, government-aligned media released an article claiming that the National Judicial Council
should be abolished for being biased. On 5 October 2023, another smear article claimed that members of theCouncil are ‘service staff of the empire’ (hinting at the United States). On 20 February 2024, the National
Judicial Council, the NOJ President, the Kúria and the prosecution service issued open letters rejecting
statements by an opposition party calling for the ‘listing’ of judges and prosecutors involved in criminal
proceedings against members of Parliament. On 20 March 2024, government-aligned media released anarticle falsly ‘accusing’ the former president of the National Judicial Council of having terminated the pretrial arrest of a person charged with possessing child pornography.
Statements of the Hungarian Association of Judges (23 February 2024) and of the National Judicial Council(27 February 2024). According to stakeholders, this measure could have a chilling effect on judges withconsequences for the content of their decisions. According to the Government, following the completion of
the internal investigation deemed necessary to clarify the editing principles, the Kúria President terminatedthe suspension still in February 2024.
Judgment of the European Court of Human Rights of 23 June 2016, Baka v Hungary, 20261/12. The Court
found that the impugned measures had a ‘chilling effect’, discouraging not only the applicant, but also ‘otherjudges and court presidents […] from participating in public debate on […] issues concerning theindependence of the judiciary’ (§ 173).
CM/Del/Dec(2024)1501/H46-15.
2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 8. See pillar II as
regards the possibility of judicial review of prosecutorial decisions not to open or to close an investigation incorruption-related cases.
GRECO Fourth Evaluation Round – Fourth Interim Compliance Report (9 June 2023), p. 9, paras. 54 et seq.
Section 58 of Act XVII of 2024 adding Section 37/A to Act CLXIII of 2011 on the prosecution service.

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pseudonymised version of all final decisions of the prosecution service and all other decisions(e.g. those of the investigating authorities) reviewed by the prosecution service.
Quality
Digitalisation of the justice system continues to be overall high while further investment
remains necessary. Hungary continues to rank very high in terms of digital solutions
allowing participation in court proceedings and online access to published judgments38.
However, the installation of necessary new terminals for hearings taking place via
videoconference has not continued, even though judges increasingly schedule such
hearings39. Stakeholders report that no new tools or technologies (e.g. speech-to-text
applications) have been introduced to counterbalance the shortage of court staff and that
outdated devices (such as laptops) are rarely being replaced40.
The National Judicial Council has made a new legislative proposal to the Ministry ofJustice to increase judicial salaries and ensure automatic indexation, considering thatthe level of remuneration of judges and court staff has further deteriorated due to highinflation. As noted in the 2023 Rule of Law Report41, the Government has not yet taken adecision to increase the real value of judicial salaries. The salaries for judges, prosecutors, aswell as court and prosecutorial staff were last increased in January 202242; since then,inflation has exceeded 37%43. Junior judges perceive the attractiveness of their salaries as
low, with reports of related resignations shortly after hiring44. This negatively impacts thecapacity of the judiciary to recruit and retain competent staff. Salaries for court staff barely
reach the minimum wage and do not substantially increase for staff with significant work
experience45. The number of judges further decreased in 2023, and the number of applicants
38
39
40

41
42

43

44

45

See Figures 46 to 48, 2024 EU Justice Scoreboard.
Contribution from the Hungarian Association of Judges for the 2024 Rule of Law Report, p. 17.
Contribution from Magistrats Européens pour la Démocratie et Libertés (MEDEL) for the 2024 Rule of Law
Report, p. 16. The overall budget allocated to courts has decreased from 2023 to 2024 by 3%, from around
HUF 160.38 billion (EUR 405 583 795) in 2023 to around HUF 155.66 billion (EUR 393 647 422) in 2024.
2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 9.
Between 2020 and 2022, judicial salaries were increased in three stages, with an overall increase of around60 %.
Since 1 January 2022, the statutory salary base of judges and prosecutors has been HUF 566 660 (EUR
1 433). Judicial salaries are calculated by appying to the salary base various multiplying factors determinedby law. Inflation stood at 15.3% in 2022, 17% in 2023 and is expected to stand at 4.5% in 2024, which posesa general challenge for public administration. The European Association of Judges ‘[c]onsiders that thecurrent levels and conditions of remuneration of judges in Hungary is contrary to European and otherinternational standards and is not compatible with the requirements established by decisions of the Court ofJustice of the European Union’ (European Association of Judges (2024), Resolution on Judicial
Remuneration in Hungary).
Information received in the context of the country visit to Hungary from Buda Central District Court;
contribution from Res Iudicata Association for the 2024 Rule of Law Report, p. 14. Junior judges (‘bírósági
titkárok’) (‘legal secretaries’ in RRP milestone 169) are court staff having passed the bar examination andtasked with certain judicial functions determined in the case allocation scheme.
Several courts struggle to fill vacancies (contribution from Res Iudicata Association for the 2024 Rule of
Law Report, p. 14). Many staff members are leaving the court, especially in the central region, because of
the extreme low salary, the increasing workload and the tense atmosphere (contribution from Magistrats
Européens pour la Démocratie et Libertés (MEDEL) for the 2024 Rule of Law Report, p. 16). The salary ofcourt staff consists of a basic salary (calculated on basis of judicial salary base) to which various
supplements can be added. From 1 December 2023, the basic salary was at least gross HUF 266 800 (EUR675) or HUF 326 000 (EUR 824) if the post requires secondary education. For a staff member with 35 years

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for initial positions does not always allow to fill all vacancies46. To address the situation, on
26 February 2024, the National Judicial Council made a new legislative proposal on theincrease and automatic indexation of judicial salaries, which is currently being considered by
the Ministry of Justice47.
Concerns remain as regards the effectiveness of the legal aid scheme in both civil andcriminal cases. The eligibility threshold for legal aid in civil procedure is high48 leading, in
general, to concerns as regards the inclusiveness of the legal aid scheme49. Fees for defence
lawyers under the legal aid scheme are regarded as critically low50, impacting access tojustice and the right to a fair trial. Also, as reported last year, access to justice could be
improved through specific arrangements for persons at risk of discrimination, for elderly
persons and for women victims of violence51.
Efficiency
The efficiency of the judiciary in civil, commercial and administrative cases continues toremain high52. As in previous years, Hungary performs very well as regards the estimatedtime needed to resolve litigious civil and commercial cases at all court instances, as well as
administrative cases at all court instances53. According to the Government, the backlog ofcases has been reduced further54. Cases with lengthy proceedings cluster in courts in thecentral region around Budapest55, where the overall caseload tends to be higher.

46

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48
49

50

51

52

53
54
55

of experience, the net salary is around HUF 270 000 (EUR 683) (contribution from Amnesty International
Hungary and eight other CSOs for the 2024 Rule of Law Report, p. 24).
Contribution from the Hungarian Association of Judges for the 2024 Rule of Law Report, p. 17. For 35
trainee positions nationwide in 2023, only 43 applicants applied, of which 35 passed the entrance exam andonly 24 positions were filled.
Information received in the context of the country visit to Hungary from the Government. The National
Judicial Council proposed to raise the salary base for judges by 35% as of 1 January 2024, to introduce
automatic indexation of the salary base as of 1 March 2025 and to raise as of 1 January 2025 the special duty
allowance payable to judges working at lower-level courts. In the budget planning period, the Kúria
President indicated the need for an inflation-linked salary increase for judges and court staff (written
contribution from the Kúria in the context of the country visit to Hungary).
Contribution by Amnesty International for the 2024 Rule of Law Report, p. 23.
Contribution by Amnesty International for the 2024 Rule of Law Report, p. 23, see also the 2023 Rule of
Law Report, Country Chapter on the rule of law situation in Hungary, p. 9.
Contribution from the Hungarian Association of Judges for the 2024 Rule of Law Report, p. 17. See also
Figure 24, 2024 EU Justice Scoreboard.
See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 9. In its 2023
concluding observations on Hungary, the UN Committee on the Elimination of Discrimination against
Women noted with concern persistent barriers to women’s and girls’ access to justice, in particular for
women and girls facing intersecting forms of discrimination who have limited access to justice owing tosocial stigma, the inaccessibility of the judicial system and gender bias among law enforcement officers,
including the police (contribution from UN Human Rights Regional Office for Europe for the 2024 Rule of
Law Report, p. 45).
Figures 5 to 11, 2024 EU Justice Scoreboard and 2023 Rule of Law Report, Country Chapter on the rule oflaw situation in Hungary, p. 9.
Figures 7 and 8, 2024 EU Justice Scoreboard.
Contribution by the Hungarian government for the 2024 Rule of Law Report, p. 7.
For example, in the Criminal Department of the Budapest Regional Court, the rate of proceedings withlength of more than two years has increased from 10 % to 35 % in five years (contribution from Res Iudicata
Association for the 2024 Rule of Law Report, p. 16).

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There were no further developments regarding a compensation scheme for cases
involving protracted administrative and criminal proceedings. The 2021 Act on
pecuniary compensation for delay in civil proceedings56 guarantees in principle genuine
redress for violations of Article 6 of the European Convention on Human Rights. However,the law does not cover non-contentious civil proceedings, such as enforcement proceedings57,
administrative and criminal cases. On 13 June 2024, the Council of Europe’s Committee of
Ministers ‘noted with grave concern the continued absence of a reaction to the Committee’s
decisions regarding the outstanding criminal, administrative, and non-contentious civil
compensatory remedies’58. According to stakeholders, the protraction of court proceedings incertain high-profile criminal cases is imputable to malfunctions of court administration59.
II.

ANTI-CORRUPTION FRAMEWORKThe Ministry of Interior is responsible for the overall coordination of the anti-corruption
policy and oversight over the National Protective Service60. As a law enforcement agency,
the National Protective Service is still in charge of crime prevention and detection, lifestylemonitoring and integrity testing for staff subordinated to the Ministry of Interior61. The
Constitution Protection Office, a national security agency overseen by the Prime Minister’s
Cabinet Office, is empowered to carry out integrity tests for all other public officials62. The
Integrity Authority is an independent authority set up based on the commitments under theconditionality procedure and the Recovery and Resilience Plan to enhance oversight overpublic spending with a focus on EU funds63. Similarly, the Anti-Corruption Task Force was
set up to examine existing anti-corruption policies and to elaborate new proposals64. The
56
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58

59

60

61

62

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Act XCIV of 2021.
Joint contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law
Report, p. 28. The sanction regime for non-execution of court decisions in press rectification, personality
rights and freedom of information cases lacks dissuasive effect, leading to excessively long enforcement
proceedings (contribution from Hungarian Helsinki Committee for the 2024 Rule of Law Report, p. 44).
Interim Resolution CM/ResDH(2024)119. See also joint contribution from Amnesty International Hungary
and eight other CSOs for the 2024 Rule of Law Report, p. 28.
Contribution from Transparency International Hungary for the 2024 Rule of Law Report, p. 12. In particular,
certain cases have been pending before the first-instance courts for years because they have been re-started
more than once following changes in the composition of the bench. The protraction of criminal proceedings
imputable to the authorities may lead to a more lenient criminal sanction.
A department of the National Protective Service is entrusted with corruption prevention tasks, including
intra-governmental cooperation and evaluation of the 2020-2022 anti-corruption strategy and action plans.
Since 1 January 2021, the Service has been in charge of corruption prevention in the health care and, since 1
July 2020, the public education sectors.
Following April 2022, the competence of the National Protective Service was reduced to a significant extent;
for more information see further below in this text on integrity tests.
Act IV of 2022 amending certain Acts related to Act II of 2022 on the list of Ministries of Hungary. Since 25
May 2022, corruption prevention in the National Tax and Customs Administration is under the competenceof the Constitution Protection Office (input from Hungary for the 2023 Rule of Law Report, p. 19).
Setting up the Integrity Authority is a commitment under the conditionality procedure (corresponding to
RRP milestone 160). In this context, a new internal audit directorate has also been set up within thegovernment body coordinating EU funds to strengthen internal controls to prevent the misuse of EU funds(RRP milestone 224). The Directorate-General for Auditing European Funds has been transformed in anautonomous body from the Ministry of Finance (RRP milestone 225).
Setting up the Task Force is a commitment under the conditionality procedure (corresponding to RRP
milestone 166). The Task Force is mandated to examine existing anti-corruption measures and to elaborate
proposals to enhance the detection, investigation, prosecution and sanctioning of corrupt practices. It
includes an even number of government and non-governmental members. Delegate members who participate

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State Audit Office contributes to corruption prevention with its competences for the audit of
the financial management of public funds, the monitoring of state-owned companies’
compliance with statutory public disclosure obligations, as well as political party finance andcampaign finance audits. As to the repression of corruption, the police can investigate private
sector corruption and corruption-related economic crimes. The investigation and prosecutionof corruption in the public sector fall under the exclusive competence of the Central Chief
Investigating Prosecution Office and its six regional offices65. The prosecution service
oversees investigations and is supported by the investigative forces of the police and the
National Protective Service.
The perception among experts and business executives is that the level of corruption in
the public sector remains high. In the 2023 Corruption Perceptions Index by Transparency
International, Hungary scores 42/100 and ranks 27th in the EU and 76th globally66. This
perception has been relatively stable over the past five years67. The 2024 Special
Eurobarometer on Corruption shows that 88% of respondents consider corruption widespreadin their country (EU average 68%) and 24% of respondents feel personally affected bycorruption in their daily lives (EU average 27%)68. As regards businesses, 78% of companies
consider that corruption is widespread (EU average 65%) and 41% consider that corruption isa problem when doing business (EU average 36%)69. Furthermore, 40% of respondents findthat there are enough successful prosecutions to deter people from corrupt practices (EUaverage 32%)70, while 25% of companies believe that people and businesses caught forbribing a senior official are appropriately punished (EU average 31%)71.
While the implementation of some remedial measures put forward in response to the
EU conditionality procedure is ongoing, important shortcomings remain and no newmeasures were adopted to remedy the outstanding concerns. To protect the EU budget
against corruption and systemic rule of law issues, on 15 December 2022 the Council, on a

65

66

67

68

69

70
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in the Task Force meetings, but do not have a voting right, include the State Audit Office, the Competition
Authority, the Public Procurement Authority, the Authority for the Supervision of Regulated Activities, theNational Office for the Judiciary and the prosecution service. Other relevant actors, such as the Government
Control Office, the National Data Protection and Freedom of Information Authority, the Commissioner for
Fundamental Rights and the Hungarian National Bank, are so far not participating in the work of the Task
Force.
As of 1 November 2023, the Budapest Investigating Prosecutor’s Office, previously under the control of the
Budapest Prosecutor’s Office, was integrated into the regional investigative bodies of the Central Chief
Investigating Prosecution Office. The primary objective of the change was to address workload imbalances
and the burden of the regional investigating prosecution offices.
Transparency International (2024), Corruption Perceptions Index 2023. The level of perceived corruption iscategorised as follows: low (the perception among experts and business executives of public sector
corruption scores above 79); relatively low (scores between 79-60), relatively high (scores between 59-50),high (scores below 50).
In 2019, the score was 44, while, in 2023, the score is 42. The score significantly increases/decreases when it
changes more than five points; improves/deteriorates (changes between 4-5 points) and is relatively stable(changes from 1-3 points) in the last five years.
Special Eurobarometer 548 on Corruption (2024). The Eurobarometer data on citizens’ corruption perception
and experience is updated every year. The previous data set is the Special Eurobarometer 534 (2023).
Flash Eurobarometer 543 on Businesses’ attitudes towards corruption in the EU (2024). The Eurobarometerdata on business attitudes towards corruption as is updated every year. The previous data set is the Flash
Eurobarometer 524 (2023).
Special Eurobarometer 548 on Corruption (2024).
Flash Eurobarometer 543 on Businesses’ attitudes towards corruption in the EU (2024).

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proposal from the Commission, temporarily suspended EU funds under several EU
programmes72 and prohibited entering into new legal commitments with public interest
trusts73, until further reforms are introduced. Pursuant to the procedure set out in theConditionality Regulation74, Hungary may any time notify remedial measures to demonstratethat the relevant breaches of the principles of the rule of law and/or their effects or risks for
the Union budget and the Union’s financial interests have been removed. In the absence of awritten notification from Hungary, the Commission reassessed on its own motion thesituation in Hungary based on the information available. On 13 December 2023, theCommission considered that the situation that had led the Council to adopt measures had notbeen remedied and that the Union’s budget remained at the same level of risk as establishedby the Council on 15 December 2022. In its assessment, the Commission listed a number ofissues that are still outstanding, concluding that the measures adopted by the Council should
remain in place75. Furthermore, no disbursement of funds under the Recovery and Resilience
Plan can be made to Hungary until all the ‘super milestones’, including those related to thekey implementation steps of the conditionality procedure, have been satisfactorily
implemented.
A new National Anti-Corruption Strategy and Action Plan is now in place 76. On 14
February 2024, Hungary adopted the medium-term National Anti-Corruption Strategy for2024-2025 and its related Action Plan, applicable as of 15 February 202477. On process, thedraft had been consulted with some key international stakeholders, but national consultations
appear to have remained limited78. On substance, the strategic documents envisage measuresrelated to new ethical standards for public officials on conflicts of interest, asset declarations,and political party financing79. The goal is to put forward a whole-of-society approach in thefight against corruption. While this is beneficial, it remains to be seen in the implementation
if this new strategic framework can effectively address systemic weaknesses in public
institutions and state organs as public service providers. As noted also by the OECD and theCouncil of Europe, a comprehensive and strategic policy approach to effectively tacklingcorruption, including high-level corruption, remains missing from the strategy. Most integrity
and corruption prevention measures target low and mid-level officials and the integrity
72
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75
76

77

78

79

See, in particular, Article 2(1) of Council Implementing Decision (EU) 2022/2506.
Public interest trusts receive significant public funding and have been found to be managed by board
members close to the Government (2023 Rule of Law Report, Country Chapter on the rule of law situationin Hungary, p. 22). Hungary has not adopted any new remedial measures with a view to addressing the
weaknesses in relation to public interest trusts.
Council Implementing Decision (EU) 2022/2506 of 15 December 2022. Article 7 of the Conditionality
Regulation provides for a specific procedure to adapt or lift the measures adopted by the Council if theMember State remedies the situation - in part or in full - that had led to the adoption of Council measures.
Commission Decision C(2023) 8999 final of 13 December 2023.
Apart from the new National Anti-Corruption Plan for 2023-2025, a separate Anti-Fraud and AntiCorruption Strategy specifically for the protection of EU funds entered into force in 2022, which theGovernment committed to coordinate. See also the commitments under RRP milestones 178, 179, 220, 221.
Government Decision 1025/2024 of 14 February 2024 on the adoption of the medium-term National AntiCorruption Strategy for 2024-2025. The draft strategy was prepared by the National Protective Service.
The draft was consulted with the European Commission, the OECD, the Council of Europe, the national
Anti-Corruption Task Force and a few selected national stakeholders. On 13 June 2023, the Anti-Corruption
Task Force adopted an opinion on the draft strategy (Anti-Corruption Task Force (2023), Complementary
Report on the draft medium-term National Anti-Corruption Strategy for 2023-2025). On 16 October 2023,
the Minister of Interior sent a letter explaining why the Government did not to take up certain proposals(Minister of Interior (2023), Letter to the chairperson of the Anti-Corruption Task Force).
For more details on lobbying, revolving doors and political party finance, see further below in this text.

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framework applicable to persons with top executive functions remains weak80. As regards thegovernance framework, the Anti-Corruption Task Force is tasked to help evaluate theprogress as regards the implementation of the Action Plan81. A final government assessment
report of the level of implementation to be prepared by the Ministry of Interior is planned for202682.
The Integrity Authority reports certain obstacles to fulfilling its oversight tasks
effectively, and the impact in practice of the proposals made by the Anti-Corruption
Task Force remains to be seen. Largely, the Integrity Authority seems to have the adequate
capacity and the necessary level of independence to carry out its work83. It referred two cases
to the prosecution service in 2023, one following a whistle-blower report and the otheridentified through its own risk assessment84. On 29 June 2023, the Integrity Authority
published its first annual analytical integrity report covering 202285, and on 14 December
2023 its position86 on the Government’s reply to the report87. The Government responded
positively to about a quarter of the recommendations issued by the Integrity Authority,committing to take further action88. In practice, some obstacles remain, particularly where theAuthority needs to rely on cooperation with other public bodies 89. In addition, the Authority
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OECD (2023), A strategic approach to public integrity in Hungary: The 2023-2025 National AntiCorruption Strategy and Action Plan; Council of Europe (2023), Hungary: anti-corruption group calls formeasures to prevent corruption in central government and law enforcement.
This requires measurable progress and impact indicators and a sufficiently high level of transparency. The
strategy does not contain a plan for communications to internal and external stakeholders about its
implementation, as also highlighted by the OECD (OECD (2023), A strategic approach to public integrity in
Hungary: The 2023-2025 National Anti-Corruption Strategy and Action Plan, p. 8). Stakeholders havecriticized the implementation of the previous strategy for not being done transparently (information received
in the context of the country visit to Hungary from K-Monitor and Transparency International Hungary). See
also 2023 and 2021 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 10(2023), p. 11 (2021).
This would be in the first quarter of the year 2026, see RRP milestone 179.
Information received from the Integrity Authority in the context of the country visit to Hungary.
Written contribution from the Integrity Authority in the context of the country visit to Hungary. Also, theAuthority initiated proceedings in two cases and submitted one administrative appeal against a decision of
the Public Procurement Arbitration Board; it notified the Hungarian Competition Authority in one case,which led to the opening of a competition procedure; and requested the designated managing authority toinitiate an irregularity procedure in two cases.
Integrity Authority (2023), Annual Analytical Report, (29 June 2023).
Integrity Authority (2023), The position of the Integrity Authority regarding the Government’s answer (14December 2023).
Hungarian Government (2023), The Government’s positions as regards the findings of the Integrity
Authority’s 2022 annual analytical integrity report.
Out of 49 recommendations, the Government fully agreed to take action in about one dozen (13) anddisagreed with 21 recommendations, while no action will be taken with regard to 5 other recommendations,where the Government does not see a need to act or takes only note. Pursuant to Section 13 of Act XXVII of
2022, the Government is not required to agree with all of the recommendations, but it must reply to theIntegrity Authority and explain how it will address the findings made in the annual analytical integrity
report.
Information received from the Integrity Authority in the context of the country visit to Hungary. The
Authority has established working relations with the relevant authorities and is empowered to act in case of
detected irregularities affecting EU funds and to initiate proceedings to be conducted by other public bodies,such as the Committee of Immunities in the Parliament, the Tax and Customs Administration or the police,
while it cannot impose sanctions itself. In addition, to enhance cooperation with other public bodies, theIntegrity Authority proposed to amend and mirror the powers it has under the Act XXVII of 2022
establishing the Integrity Authority also in sectoral laws.

15

www.parlament.gv.atreported that it does not have direct access to all the data registers containing information that
may be needed for it to carry out its tasks90 and in certain cases no such data is available91. To
enhance cooperation with other public bodies that it heavily relies upon, the Integrity
Authority has proposed to the Government to mirror its powers92 also in sectoral laws93.
Stakeholders also highlighted the need for a strategy for the Authority, including thedefinition of criteria for the selection of cases for investigation94. The Anti-Corruption Task
Force, created to support the Government’s overall anti-corruption policy coordination,
adopted its second annual report95. Non-governmental members of the Task Force expressed
concerns as regards its capacities96, scope and the Government’s limited uptake of proposals
and questioned the Task Force’s meaningful impact in practice97.
The possibility of judicial review has reportedly led the prosecution service to assess thefollow-up on crime reports more thoroughly, even though court decisions overturning
prosecutorial decisions remain non-binding98. A year after its introduction, Hungary has
started the revision of the possibility for a judge to review prosecutorial and investigative
authorities’ decisions not to investigate reported corruption suspicions or to terminate
ongoing corruption investigations without indictment99, which has been in force since 1
90

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95

96

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98
99

E.g. the central register on beneficial ownership managed by the Tax and Customs Administration, wheredata can only be provided upon targeted request. Overall, the Integrity Authority reports that, where there isno direct access, the requested data received from other institutions and entities is at times fragmented,
partially incomplete, and often unchecked. Regarding the responses to data requests, the speed, ability,
quality, and usability of the data poses obstacles to the effective operations and fulfilment of the Authority’stasks (Integrity Authority (2023), 2022 Annual Analytical Report, p. 5). The Government reports that work is
ongoing to allow for direct access, with closer cooperation between the Integrity Authority and the Tax andCustoms Administration having started in January 2024 (information received in the context of the country
visit to Hungary from the Ministry of Justice).
The Integrity Authority has no access to beneficial ownership information on private equity funds because,in line with national law adopted in 2022, information about the investors/beneficial owners has been
removed from the register maintained by the Tax and Customs Administration; the Hungarian National Bank
only verifies ownership at the moment of the authorisation and registration process but does not record suchdata (written contribution from the Integrity Authority in the context of the country visit to Hungary).
As stipulated in Act XXVII of 2022 establishing the Integrity Authority. Other institutions and entities seemto apply only the sectoral legislation regulating their activity which does not refer to the Authority’s directaccess to their data bases or the obligation to cooperate with the Authority. This could be solved by‘mirroring’ the relevant provisions of Act XXVII of 2022 in the sectoral legislation concerned.
Integrity Authority (2024), Annual Report to the Hungarian National Assembly 2023, p. 9, including a set ofrecommendations to enhance the protection of the EU budget, p. 11.
Information received in the context of the country visit to Hungary from K-Monitor and Transparency
International Hungary. See also Hadházy, Ákos (2024), Facebook post of 29 January 2024.
The Task Force adopted its annual report covering the year 2023 at its meeting held on 12 March 2024. The
Government replied on 10 June 2024. According to the Government, it supported all consensual proposals
which prescribed tasks for the Government.
Three out of ten non-governmental members had resigned, with Hungary reporting that the remaining two
vacancies were filled in February 2024.
Three non-governmental members of the Task Force voted against the Task Force’s second annual report.
See Task Force (2024), 2023 Report of the Anti-Corruption Task Force; and Átlátszó (2024), Átlátszó, KMonitor and Transparency have not accepted the annual report of the Anti-Corruption Working Group. The
Government is not obliged to follow the proposals of the Task Force, but to provide a justification not to doso (K-Monitor (2023), Anti-Corruption Task Force: what is the situation eight months after its launch?). See
also K-Monitor and Transparency International Hungary (2024), Special report on the 2023 Anti-Corruption
Task Force Report: Current issues in the fight against corruption in Hungary.
Information received in the context of the country visit to Hungary from the prosecution service.
Input from Hungary for the 2024 Rule of Law Report, p. 15.

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January 2023100. The Prosecutor General has published guidelines, including instructions how
to file a review request, which stakeholders have found to be user-friendly101. However,shortcomings remain in particular as regards the temporal scope of the new measure102 andthe lack of the binding nature of court decisions quashing the prosecutor’s decision not toprosecute103. Stakeholders have also raised concerns as to its results in practice104. Until 29
February 2024, 74 motions for judicial review had been filed with the competent Buda
Central District Court105; most of them were allegations of abuse of office, unrelated to publicfunds106.
Integrity tests and lifestyle monitoring remain the main tools to detect and deter
corruption, although their effectiveness is limited in detecting high-level corruption.
Also in 2023, reliability testing through integrity surveillance and testing of public officials
was reported to be the primary tool used to detect corruption in the public sector107. In
practice, this has been effective primarily for petty corruption cases, such as gratitude
payments in healthcare108. Other tools that could be more effective in detecting a wider
variety of corruption cases (including high-level corruption), such asset declarations,100

A government assessment report on the functioning of the judicial review planned for the fourth quarter of2023 is still pending. The possibility of judicial review was introduced in the Criminal Procedure Code by
Act XLIV of 2022 to enhance the effective prosecution of corruption by addressing the concerns raised in
the past as regards the accountability of the prosecution service (see 2022 and 2023 Rule of Law Reports,
Country Chapter on the rule of law situation in Hungary, pp. 9, 15-16 (for 2022), and p. 13). Anyone canrequest a review and trigger the oversight procedure for any corruption-related cases dismissed or terminatedafter 1 January 2023. If the prosecution service does not grant the request, the judge can decide that an
investigation should take place or should be continued and send the case back for investigation to theprosecution service. If the prosecution service does not act, the judge informs the person who has requested
the review that they can represent an indictment before the court.
101
Information received in the context of the country visit to Hungary from K-Monitor.
102
The new law does not clarify the scope of application in time of the new rules and, in particular, fails toclarify that the new procedure will also apply to (non-time-barred) criminal offences committed before 1
January 2023. See Council Implementing Decision (EU) 2022/2506 of 15 December 2022, recital 46.
103
The prosecution service is only obliged to take the court decision into account. See Council Implementing
Decision (EU) 2022/2506 of 15 December 2022, recital 46.
104
See for example K-Monitor (2023), Anti-corruption criminal procedure reform: the rules are there, but thepractice is unchanged (15 December 2023).
105
Of the 74 motions, the court considered 43motions, rejected 37 and granted a motion for review in 6 cases
until 29 February 2024. In addition, the court received one repeated motion for reconsideration, which was
also dismissed. Until 1 November 2023, no motion for prosecution was filed, see K-Monitor andTransparency International Hungary (2023), Special report on the 2023 Anti-Corruption Task Force: Current
issuesinthefight
againstcorruptionin
Hungary. According
toits
website(https://integritashatosag.hu/ugyek/felulbiralati-inditvanyok/felulbiralati-inditvanyok-2/),
theIntegrity
Authority has filed five motions for revision, two of which were successful. In one case, the prosecution
decided to continue the investigation, and in another case, the court overturned the investigative authority’s
decision to drop the procedure. One of the motions has been rejected by the Buda Central District Court. The
Integrity Authority has filed one repeated motion for revision, which is still pending.
106
Information received in the context of the country visit to Hungary from the prosecution service.
107
Information received in the context of the country visit to Hungary from the prosecution service.
108
Gratuity payments in the health care sector are reported to be the most serious disturbance and challenges
that the National Protective Service is in charge of, with a total of 218 cases of corruption and other criminal
offences in the health sector having been reported or investigations been initiated against 1 354 persons in
the course of 2023 (input from Hungary for the 2024 Rule of Law Report, p. 12). In its RRP, Hungary
committed to implement an awareness-raising campaign against gratuity payments (RRP milestones 182-183
and target 184).

17

www.parlament.gv.atwhistleblower disclosures and registers109, continue to play a relatively minor role incorruption investigations110. The National Protective Service continues to be considered
indispensable to gather evidence essential for initiating corruption investigations andprosecutions111. It is tasked with carrying out integrity tests and lifestyle monitoring for staff
subordinated to the Ministry of Interior and other public administrative bodies112. For the
integrity testing of all other public officials conducted by the Constitution Protection Office,risks to the transparency of such proceedings, as previously reported, has materialised in thereporting period113. Information or data about reliability testing, including numbers ofcorruption suspicions reported to the prosecution service, is no longer publicly available forthose public officials who are covered by the mandate of the Constitution Protection
Office114.
Whereas the number of convictions for corruption-related crimes has increased in low
level corruption cases, there has been no progress yet to establish a robust track record
against high-level corruption. The 2022 and 2023 Rule of Law Reports recommended to
Hungary to ‘[e]stablish a robust track record of investigations, prosecutions, and final
judgments for high-level corruption cases’115. The prosecution service continues to view thelevel of cooperation between the relevant state entities combating corruption, as well as
human and financial resources, and specialisation as adequate to carry out their tasks116. The
new IT system for the prosecution service, planned to address the persisting challenge inevidence-gathering and sharing, is still not in place and is now planned to be operational by109

The central register for beneficial ownership information managed by the Tax and Customs Administration isaccessible only to those who have a legitimate interest to the central register. Access has been granted in thismanner since 1 July 2022. Stakeholders had warned in previous years that excessive fees and too strict
accessibility criteria set by the Administration would deter ordinary citizens from using the central database.
Information received in the context of the country visit to Hungary from K-Monitor and Transparency
International Hungary. Transparency International recommend increased transparency of private equity
funds, which play a role in hiding ill-gotten gains from corruption (Transparency International (2022),
Exporting Corruption, p. 52). The EU legislation on anti-money laundering and counter terrorist financing
imposes obligations on all Member States to identify the ultimate beneficial owner. Beneficial owners areindividuals who benefit from a company even though they are not formally named as owner of the business.
110
Information received in the context of the country visit to Hungary from the prosecution service. See also
contribution from K-Monitor for the 2022 Rule of Law Report, p. 18. This is the case since 2021 (see 2021
Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 12).
111
See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 14.
112
These include employees of territorial government bodies and specialised territorial child protection
services, as well as the state employed health care staff.
113
Since the Constitution Protection Office is a national security service, the potential detection of corruption
by this Office can fall under national security rules and thus remain undisclosed. As a result, the decision not
to further pursue a corruption investigation is de facto impossible to review, with corruption cases risking not
to be pursued. See also 2023 Rule of Law Report, Country chapter on the rule of law situation in Hungary, p.
14 with further stakeholder references. Other than for the National Protective Service, no data on detected
corruption cases was shared or is available from the Constitution Protection Office.
114
The Constitution Protection Office, overseen by the Prime Minister’s Cabinet Office, performs the integrity
tests of the officials and employees of governmental bodies (e.g. ministries), with the exception of themilitary and the officials and employees of governmental bodies (e.g. the Police, the penitentiary system)and sectors (e.g. healthcare, public education) overseen by the Minister of Interior.
115
2022 and 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2.
116
Information received in the context of the country visit to Hungary from the prosecution service. See also2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 15.

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the end of 2025117. The reported indictment rate for corruption crimes continues to be high,according to the prosecution service118, with one new indictment in 2023 also in a complex
corruption and money laundering case against a large number of defendants, including one
former high-level official119. In 2023, the prosecution service reported that 364 persons had
been convicted at a final instance for corruption-related crimes120. However, most cases target
low to mid-tier officials while leaving out the top-level officials of the country’s public
administration, and convictions in high-level corruption cases continue to be rare121.
Generally, in complex high-level corruption cases, court proceedings tend to be excessively
long122. The risk of undue interference with individual cases persists in the prosecution
service123, while also the police’s operational independence appears to be affected by politicalinfluence on the prosecution service124. Serious concerns remain therefore about the absenceof a robust track record of investigations of corruption allegations concerning high-level
officials and their immediate circle. Stakeholders also continued to raise concerns aboutclientelism, favouritism and nepotism in high-level public administration and about the riskof impunity caused by a disparity in the treatment of corruption cases for political

117

Financial data relevant for investigations is spread over numerous separate state registers. The new IT
system for the handling of sensitive documents would facilitate administrative work and data exchange fordata searches by prosecutors (information received in the context of the country visit to Hungary from theprosecution service). It was originally planned to be fully functional and operational by Q2 2024, see 2023
Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 16, and RRP milestone 180.
Also, a new case management IT system facilitating administrative work and the exchange of non-sensitive
information is planned to be fully functional and operational by the end of 2025, see RRP milestone 181.
118
A total of 1 698 procedures registered in police proceedings for corruption crimes were completed, leading
to indictment (compared to 1 224 in 2022) (input from Hungary for the 2024 Rule of Law Report, pp. 1415). See also European Anti-Fraud Office (OLAF) (2024), Annual Report 2023 for the latest data on judicial
follow-up by Member States, indicating an indictment rate in Hungary.
119
Information received in the context of the country visit to Hungary from the prosecution service, referring toan overall number of 22 defendants in this case. Allegations of evidence-tampering by the prosecution
service upon Government instructions and the obstruction of justice by the Government in this high-level
corruption case involving a former state secretary of the Ministry of Justice and the chief bailiff prompted
the prosecution service to initiate investigations for failure to report bribery, see Reuters (2024), Hungary
prosecutors probe graft case tape leaked by former government insider and Telex (2024), Former Justice
Minister’s ex-husband releases recording he claims proof of high-level involvement in corruption case. For
more details, see Intellinews (2023), Hungary’s highest-profile corruption case lifts the veil on how Orban’s
regime really operates. See also The Budapest Times (2024), KNYF: ‘No documents disappeared in socalled Volner-Schadl case’.
120
Input from Hungary for the 2024 Rule of Law Report, pp. 14-15. In 2022, there were 326 final convictions,largely for petty corruption cases.
121
Contribution from Democracy Reporting International for the 2024 Rule of Law Report, p. 4. See also
Council of Europe (2023), Hungary: anti-corruption group calls for measures to prevent corruption in central
government and law enforcement.
122
Transparency International Hungary and K-Monitor (2023), Special report on the 2023 Anti-Corruption Task
Force: Current issues in the fight against corruption in Hungary. See also 2023 Rule of Law Report, Country
Chapter on the rule of law situation in Hungary, p. 16 and footnote 104 with further references.
123
See in this context Section I above, p. 11. The full implementation of the GRECO recommendations as
regards the effective functioning of the prosecution would further strengthen the anti-corruption framework.
See GRECO Fourth Evaluation Round – Third Interim Compliance Report (2022), p. 6, paras. 31-35. This
concerns in particular the limitation of prosecutors’ immunity to functional immunity but also the procedures
to lift parliamentarians’ immunity, which risk hampering the timely evidence-gathering in corruption
investigations against parliamentarians.
124
GRECO Fifth Evaluation Round – Evaluation Report (2023), p. 29, para. 126, pointing at hierarchicalpressure on police officers to discontinue investigations in certain sensitive cases.

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purposes125. Overall, considering the lack of significant developments126, no progress wasmade on establishing a robust track record to fight high-level corruption, as recommended in
the previous years.
Enforcement against foreign bribery is still lacking. International recommendations todesign a strategy to proactively detect and investigate foreign bribery cases and to provide formore time in the application of investigation measures in highly complex multi-jurisdictional
cases remain among other recommendations unfulfilled since 2012127. The Government
considers Hungary’s legislative framework appropriate to prevent and repress foreign
bribery, focusing its activity in this area on organising trainings and on creating a framework
for improving cooperation128. While one conviction is reported129, no new investigations into
foreign bribery have been initiated during the reporting period130.
The legislative steps taken to facilitate on-the-spot checks conducted by the EU AntiFraud Office (OLAF) for investigations involving EU funds have proven effective. In
2023, based on the legislation adopted in October 2022131, OLAF requested in several
instances the National Tax and Customs Administration to secure the presence of a financeguard during OLAF’s on-the-spot checks to ensure cooperation of the economic operator
subject to the control and it received the necessary support. Following allegations of acorruption ring in managing authorities, more than 50 suspects have been brought before thecourts on bribery charges in connection with EU funds, including a former deputy statesecretary and 25 legal entities132. Furthermore, the Integrity Authority conducted successful

125

Corruption Research Center Budapest (2023), Fourteen Graphs and Two Tables on the New Trends ofCorruption in the Hungarian Public Procurement 2005-2022; information received in the context of thecountry visit to Hungary from Transparency International Hungary, K-Monitor, Corruption Research Center
Budapest and Átlátszó. There is a prevalence of informal power networks, and centralised politicalcorruption in Hungary, bolstered by economic connections within networks that revolve around a few
oligarchs with close political ties, according to Bertelsmann Stiftung (2024), Transformation Index: Hungary
Country Report.
126
See above in this Section II on oversight and control mechanisms.
127
OECD (2023), Implementing the OECD Anti-Bribery Convention, Phase 4 Evaluation of Hungary:
additional written follow-up report. See also OECD (2023), OECD Working Group on Bribery publicstatement on Hungary. Transparency International (2022), Exporting Corruption, p. 51, reporting about little
to no enforcement referencing that in the period of 2018-2021, Hungary opened one investigation,commenced no cases and concluded no cases.
128
See Government Decision 1025/2024 of 14 February 2024.
129
According to information received from the Government, in April 2024, the Budapest Regional Court
convicted a defendant for having traded in honorary consular titles of different non-EU countries.
130
Input from Hungary for the 2024 Rule of Law Report, p. 13.
131
Act XXIX of 2022 on the control of the use of European Union budget funds, which entered into force on 11
October 2022. In RRP milestone 226, Hungary committed to reforms to strengthen the cooperation with
OLAF to reinforce the detection of fraud related to the implementation of Union support.
132
Prosecution service (2024), Indictment in a case related to tender grants obtained through corruption – withvideo – press release of the Central Chief Investigating Prosecution Office. The case concerns 108 EUfunded calls for proposals and a total of HUF 25 bn grant amount sought. See also Magyar Hang (2024), 54
people indicted in corruption case involving the Ministry of Finance and the Prime Minister’s Office; 24.hu(2024), The prosecution service would send to prison Mihály Varga’s former deputy state secretary and
László Palkovics’ confidant; Forbes (2024), Here is another 25 billion forint government corruption scandal:
dozens of Mihály Varga’s former subordinates are involved. 2023 Rule of Law Report, Country Chapter on
the rule of law situation in Hungary, p. 18.

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own-initiative proceedings in at least one case concerning budget fraud, including EU
subsidies, in a case involving a high-level official and his family, finding irregularities133.
There has been no further progress on lobbying and post-employment regulation, withplans to legislate in this area only in 2025. The 2023 Rule of Law Report recommended to
Hungary to ‘[a]dopt comprehensive reforms on lobbying and revolving doors [...] providing
for effective oversight and enforcement’134. The new National Anti-Corruption Strategy
2024-2025 and Action Plan contain a commitment of the Government for a legislative
proposal on lobbying law, including rules on revolving doors, to be prepared by the Ministryof Justice by 30 November 2025135. Whether the proposal will provide for the creation of atransparency register and a legislative footprint to disclose contacts with interest
representatives in the decision-making process, which are so far missing in Hungary, is not
yet decided136. In this context, the Minister of Justice is tasked by Government decision toevaluate and prepare a report on current lobbying practices137. The Government committed
further to a non-binding Code of Conduct for persons with executive functions, including
contacts with lobbyists and post-employment restrictions138. For Parliament, no steps havebeen reported for the establishment of a clear set of rules on contacts between members of
Parliament and lobbyists to address concerns regarding the level of transparency in thedecision-making process139. Thus, Hungary’s lobbying rules remain incomplete, with nosystematic follow-up ensured in case of non-compliance140. Post-employment restrictions andcooling-off periods remain largely fragmented141 and limited in personal scope142. At thesame time, no further steps have been taken to provide for more effective enforcement 143. A
code of ethics for members of Parliament, that would include post-employment guidelines, isIntegrity Authority (2024), Conclusion of inquiry III_86_2023 – modernisation of cattle farm. For moredetails, Telex (2024), The Integrity Authority filed a complaint over the half-billion forint ‘dairy farm’ of thefamily of ex-minister János Süli. The case was already publicly reported about in 2020 (Átlátszó (2020),
Corruption info: hundreds of millions of euros in EU funding for the company of the son of the minister
responsible for the Paks investment). See however the post of the National Assembly member Hadházy,Ákos (2024), Facebook post of 29 January 2024 on alleged inactivity of the Integrity Authority. Regarding
the allegations reported about over the last two years of a corruption ring in managing authorities linked tonational and EU funds that raised concerns as to the lack of systemic oversight, see above in this section on
the track record.
1342022 and 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2.
135
Government Decision 1025/2024 of 14 February 2024. See also written contribution from the authorities in
the context of the country visit to Hungary.
136
Information received in the context of the country visit to Hungary from the Hungarian authorities.
137
Information received in the context of the country visit to Hungary from the National Assembly.
138
Information received in the context of the country visit to Hungary from the Hungarian authorities.
139
See GRECO (2022), Fourth Evaluation Round – Third Interim Compliance Report, paras. 9-10. According
to the National Assembly, parliamentary rules are clear and interest representatives have the opportunity to
express their opinions (information received in the context of the country visit to Hungary from the National
Assembly).
140
See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, pp. 18-19.
1412022 and 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary. See in thiscontext also GRECO (2023), Fifth Evaluation Round – Evaluation Report, p. 56 et seq.).
142
They apply only to a small group of officials and a limited set of public institutions, such as the State Audit
Office and the National Media and Infocommunications Authority, see 2022 and 2023 Rule of Law Report,
Country Chapter on the rule of law situation in Hungary, pp. 17-18 (for 2022) and pp. 19-20 (for 2023).
143
No sanctions are enforced in practice. The Government is still to specify the sectors and public officials’
positions to which cooling-off time restriction will apply with regard to business careers of public officials in
the area, in which they were active beforehand.
133

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planned144. Without more steps taken for a comprehensive reform on lobbying and postemployment rules, there has been no further progress on the recommendation made in theprevious years.
There has been no further progress to improve the asset declarations’ system, including
effective oversight. The 2023 Rule of Law Report recommended to Hungary to ‘further
improve the system of asset declarations, providing for effective oversight andenforcement’145. On 7 December 2023, the Integrity Authority presented an ad-hoc report on
Hungary’s asset declaration system, including an extensive set of recommendations to theGovernment146. There is no official Government reply to this report yet. The National AntiCorruption Strategy for 2024-2025 includes plans for the Ministry of Justice to create thepossibility for electronic submission of asset declarations and to propose the introduction ofan effective, proportionate, and dissuasive administrative and criminal sanctions’ regime forbreaches of asset declaration obligations147. The power to verify asset declarations has not yet
been effectively transferred and provided to the Integrity Authority148. In practice, according
to the Integrity Authority, obstacles for its oversight role remain substantial, including thelack of direct access to certain registers necessary for the effective fulfilment of its
verification tasks149. Stakeholders stressed emerging risks, with private equity funds andfiduciary asset management arrangements providing for new opportunities to potentially hideassets, as they are removed from general oversight and access by the Integrity Authority150.
144

Government Decision 1025/2024 of 14 February 2024. According to Section 85 of Act XXXVI of 2012,
restrictions apply for a period of two years after the termination of the mandate to members of Parliament toprevent economic conflicts of interest in that they are restricted to conclude a purchase agreement to acquire
shareholdings of a business organisation operating with influence over the Hungarian or foreign State, alocal government, the association of local governments, a foreign municipality, a political party, or adomestic or foreign religious community. GRECO has repeatedly called for the introduction of a code of
ethics/conduct for members of Parliament, covering, among others, post-employment rules, andcomplementary, practical measures for their implementation, see GRECO Fourth Evaluation Round – Third
Interim Compliance Report, pp. 3-4, paras. 8-11, with reference to the Fourth Evaluation Report, p. 17.
1452022 and 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2.
146
Integrity Authority (2023), Ad-hoc report on asset declarations. The report’s assessment was excluded fromthe Integrity Authority’s first annual analytical integrity report described above in this pillar I, p. 17.
147
Government Decision 1025/2024 of 14 February 2024, Chapter 1. See also written contribution from theauthorities in the context of the country visit to Hungary.
148
Hungary committed under the RRP to provide the Integrity Authority with exclusive competence to verify
the asset declarations of certain high-risk officials covered in Section 183 of Act CXXV of 2018 (including
the Prime Minister, ministers, state secretaries, political director of the Prime Minister), as well as with thepower to directly verify the public asset declarations of all high-risk officials. This is for example the casefor the asset declarations of members of Parliament, where the Committee of Immunities of the National
Assembly is tasked to verify asset declarations. For non-public asset declarations of high-risk officials, theIntegrity Authority shall have at least the power to request the competent bodies to carry out the verificationof those declarations and obtain the result of that verification.
149
Integrity Authority (2023), 2022 Annual Analytical Report, p. 152. See also above in this pillar I, pp. 17-18.
150
Information received in the context of the country visit to Hungary from the Integrity Authority, K-Monitor
and Transparency International Hungary. Even if a declarant as a beneficiary of private equity funds intends
to transparently submit information on such assets in the declaration, the declaration form does not provide
for sufficient clarity on how to report, as only shares in funds can be reported, with private equity not having
shares but beneficiaries. Furthermore, since there is no publicly available database on such assets, there is no
way to check or audit the income or the beneficiary status of equity funds. Reportedly, ministers wereencouraged by a non-public Government decision (4100/2022) to transfer their holdings in public limited
companies and small and medium-sized enterprises into such trusts. See RTL (2024), The government covers
up certain corporate assets of ministers with an undisclosed decision; 24.hu (2024), Ministerial fortunes
may remain invisible as a result of a government decision.

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With regard to asset declarations of members of Parliament, concerns persist regarding theireffective and regular monitoring and verification151. In the reporting period, no procedureagainst a member of Parliament before the National Assembly’s Immunity Committee wasinitiated, and two members of Parliament decided to correct and rectify their asset
declarations retrospectively following reports in media152. As previously reported, there is
still no obligation for regular monitoring for the respective entities in Parliament or the Tax
and Customs Administration to check the correctness and completeness of the declarations
made. Asset declarations are generally verified only upon notification of suspicions, andpotential follow-up is left to the discretion of the public official’s employer or, in case of
members of Parliament and other high-ranking officials, to the Immunity Committee.
However, neither declarations of most high-ranking officials nor information about any
follow-up are publicly available153. Other previously identified shortcomings remain
unaddressed, including more effective monitoring, verification, oversight and enforcement154.
Against this background, no progress has therefore been made towards implementing therecommendation made in the 2023 Rule of Law Report155.
Guides and awareness-raising measures on conflicts of interests are envisaged, while
legislative fragmentation and systemic weaknesses remain. The Government included in
the Action Plan of the National Anti-Corruption Strategy 2024-2025 the adoption of a Codeof Conduct for persons with executive functions156, the aim of which is to provide new softlaw rules for political and professional senior managers, their advisers, and Prime Minister’sdelegates. To increase awareness of integrity also in the National Assembly, in particular, on
conflicts of interests, gifts and benefits, the Code of Conduct is planned to cover also
members of Parliament and employees of the Office of the National Assembly157. However,in 2023, there were no developments to address the systemic weaknesses reported on in
2023158. These include, among others, the fragmentation of the regulatory framework on
conflict of interests, including the lack of a general definition of conflict of interests and the151

GRECO also found that the verification of declarations was clearly insufficient (GRECO (2023), Fifth
Evaluation Round – Evaluation Report, p. 4, para. 3). In January 2024, members of Parliament continued
largely to submit their asset declarations on paper. Of these, 63 used electronic software to complete andprint the declaration, while 136 completed the declaration on paper (written contribution from the National
Assembly in the context of the country visit to Hungary). No failures to comply within the deadline arereported.
152
Information received by the National Assembly in the context of the country visit to Hungary.
153
While the declarations of members of Parliament are publicly available, they are often scanned documents
filled out by hand, thus not being machine-readable. Furthermore, in 2023, while previously available,family members’ names in asset declarations of member of Parliament have been retrospectively removed
from all declarations published from 2010 onwards (information received in the context of the country visit
to Hungary from National Data Protection and Freedom of Information Authority).
154
See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary. See also K-Monitor(2023), Hungarian MP’s Assets: Less Declared and Still not Monitored.
155
Important weaknesses, risks and shortcomings remained as regards elements of the asset declaration system
which create possible loopholes undermining the effectiveness of the measure were also identified by theCommunication on the application of Regulation (EU, Euratom) 2020/2092 (15 January 2024). Council
Implementing Decision (EU) 2022/2506 of 15 December 2022, recital 41.
156
See above and RRP milestone 178.
157
Written contribution from the National Assembly in the context of the country visit to Hungary.
158
See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, pp. 21-23.

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absence of a central supervisory body remain so far, as also pointed out by the Integrity
Authority159.
The new whistleblower protection law for EU funds entered into force. The new law
transposing the EU Directive160 to enhance the protection of whistleblowers reporting on
potential wrongdoings relating to breaches of EU law has been in force since 24 July 2023 161.
Stakeholders flagged risks of legal uncertainty, with weaker protection levels for those casesthat concern national funds compared to those that relate to EU funds162. An accompanying
Government Decree sets out which Government bodies will be required to establish separate
whistleblower disclosure systems163 apart from the already operated online disclosure
channels164. The anonymous, secure whistleblower hotline of the Integrity Authority forcorruption, fraud and conflicts of interests related to EU funds became operational in June
2023165. Overall, some disclosures reportedly reach the respective entities, but whistleblower
reporting is not yet a widespread practice166. Also in 2023, no further steps have been taken
yet to address the major operational deficiencies in the whistleblower regime in practice,including the limited protection against retaliation and the risks of disclosure of thewhistleblowers’ identity167.
Shortcomings with regard to political party and campaign rules and their narrow scopeof application remain unaddressed. As reported last year, some measures had been taken toincrease the transparency of political party financial registries168. The Government announced
in its National Anti-Corruption Strategy 2024-2025 a review of the operations of politicalorganisations and the enforcement of political party finance rules with a focus exclusively on
preventing foreign funding of political parties169. In February 2024, the State Audit Office
imposed fines on six political parties for alleged illegal foreign funding during the 2022
election campaign170. Challenges previously identified regarding political party and campaign
159

Integrity Authority (2023), 2022 Annual Analytical Report, p. 119.
Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law.
161
Act XXV of 2023 on complaints, public interest disclosures and rules related to whistleblowing.
162
Information received in the context of the country visit to Hungary from K-Monitor and Transparency
International Hungary; K-Monitor and Transparency International Hungary (2023), Letter to the European
Commission, Possible infringements of Directive 2019/1937 on the protection of persons who reportbreaches of Union law by the Hungarian Government, noting that disclosures to media remain unprotected.
163
Government Decree 225/2023 of 8 June 2023.
164
At the Commissioner for Fundamental Rights, the National Protective Service, the Competition Authority,
the Public Procurement Authority and the Prime Minister’s Office.
165
See written contribution from the Integrity Authority in the context of the country visit in Hungary and theIntegrity Authority’s website to report: https://integritashatosag.whispli.com.
166
Anonymous whistleblowing on EU fraud can also be disclosed on the anti-lop.hu website. In 2023,
reportedly 25 whistleblowing reports were received on the website, of which three are under investigation,and ten have been rejected as unfounded or after investigation. See also the Special Eurobarometer 584 on
Corruption (2024) on the level of corruption reporting. The reluctance to report is partially due to the lack offinancial support for those who risk potential retaliation (information received in the context of the country
visit to Hungary from K-Monitor and Transparency International Hungary). Also 2023 Rule of Law Report,
Country Chapter on the rule of law situation in Hungary, p. 23.
167
See OECD (2021), Implementing the OECD Anti-Bribery Convention, Phase 4 Two-Year Follow-Up Report:
Hungary, p. 3. The general prohibition of retaliation of the new, enforced Act applies only to whistleblower
disclosures related to subject-matters in EU legal acts.
1682023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, pp. 24-25.
169
See Government Decision 1025/2024 of 14 February 2024.
170
State Audit Office (2024), Partial Audit Report. Bloomberg (2024), Hungary Clamps Down on Orban’s
Opponents with Hefty Fine. Intellinews (2024), Hungarian State Audit Office fines opposition parties for160

24

www.parlament.gv.atfinancing rules171 have not been addressed in the reporting period and no actions in thisregard are planned under the Strategy and Action Plan. Overall concerns therefore remain as
regards the transparency of party financing172.
New obstacles to the transparency of public procurement appeared, while different
levels of control exist for national and EU-funds related procurements. Businesses’
attitudes towards corruption in the EU show that 29% of companies in Hungary (EU average27%) think that corruption has prevented them from winning a public tender or a public
procurement contract in practice in the last three years173. Some measures to enhancecompetition in public procurement are included in the National Anti-Corruption Action Plan
for 2024-2025174. The members of the Anti-Corruption Task Force report that most of the
proposals made in its report related to public procurement did not receive support by theGovernment175. Stakeholders report that since autumn 2023, new obstacles have appeared fortransparency of public procurement176, highlighting practical challenges. For instance, theyreport that a new feature renders the bulk download of data on public procurement, and hence
statistical analysis concerning risks of corruption and political favouritism, difficult177. This
restricts possibilities for public monitoring. Corruption risk sectors remained largely the same
compared to previous years, with high risks in public procurement, construction, health, IT,

alleged foreign campaign finance. There are no legal possibilities to appeal the findings. Parties are subject
to the prohibition of foreign funding. The Protection of National Sovereignty Act extended this prohibition to
non-profit organisations which are now prohibited from accepting foreign funding and from using
anonymous election donations or financial support from non-legal persons. The definition of foreign funding
has a broad scope, encompassing not only financial contributions from other state and foreign natural or
legal persons, but also already the provision of trainings.
171
Including the narrow scope of application, campaign activities that are conducted outside the official
campaign period, systemic overspending on outdoor billboard advertising during the 2022 elections, political
advertising on the social media platform Facebook, financed by third parties and intermediaries, including
the conservative social media incubator Megafon Centre training pro-government influencers and promoting
their posts as one of the largest spenders on political ads on Facebook in the election campaign, see 2023
Rule of Law Report, Country Chapter on the rule of law situation in Hungary, pp. 24-25; on the level of
spending, see Lakmusz (2024), How does anyone who is not a friend of Fidesz become a ‘leftist’; and Telex(2024), SAO: CÖF and Megafon said that they had not cooperated with Fidesz.
172
See in this context also OSCE ODIHR and Venice Commission (2020), Guidelines on Political Party
Regulation, Second Edition, para. 194; OSCE ODIHR (2022), Hungary Parliamentary Elections andReferendum - 3 April 2022 - ODIHR Election Observation Mission Final Report, p. 22. State Audit Officeaudit findings cannot be challenged before an administrative court. See also GRECO (2019), Third
Evaluation Round – Second Addendum to the Second Compliance Report, para. 24.
173
Flash Eurobarometer 543 on Businesses’ attitudes towards corruption in the EU (2024), Report, IV.
Reporting of Corruption.
174
Government Decision 1025/2024 of 14 February 2024, Chapter 5. See also European Commission (2024),
2024 Country Report Hungary, pp. 9 and 62 for further measures to enhance competition.
175
See K-Monitor and Transparency International Hungary (2024), Special report on the 2023 Anti-Corruption
Task Force Report: Current issues in the fight against corruption in Hungary.
176
The new website of the Public Procurement Authority uses ‘captcha’ barriers, introduced to address IT
security issues, which however limit machine-readability and comparability of vast amount of data by public
monitors.
177
Due to this new feature, public monitors, such as researchers and civil society, incurred extra costs, in orderto still be able to obtain big data to continue their analysis of corruption risks and patterns in procurement
over time. Information received in the context of the country visit to Hungary from Transparency
International Hungary, K-Monitor and Corruption Research Center Budapest, indicating that the bulk
download is now more difficult, as it would now have to be done manually step-by-step, as users can only
log-in for a limited period of time, with repeated requests to authenticate again with ‘captcha’.

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and communication services178. National legislation does not allow public entities to conclude
contracts with or make payments to non-transparent entities. However, stakeholders reportabout emerging risks concerning transactions through non-transparent structures withtransactions often being concluded through private equity funds or trust funds, preventing the
public disclosure of their beneficial owners and change in ownership in practice 179. This
uncertainty creates a challenge for the supervisory authority to track compliance with loan
limits to companies owned by the owner of the bank. It also makes it difficult for the public
to monitor the use public money if the state sells companies or concludes tender contracts
with private equity funds180. Overall, corruption risks were found to have increased in 2023
for public tenders related to national funds that are not controlled by the EU and thus where
different levels of control and oversight applies181. In this context, high corruption risks wereidentified in particular for the local level and municipalities, indicating examples of howpolitical networks can lead to abuse of tender processes, including favouritism due to close
ties between business and politics182. Stakeholders continue to report about selective
awarding to political affiliates183, which carry the potential to increase corruption risks in a
procurement market that is already vulnerable to corruption184.
III.

MEDIA PLURALISM AND MEDIA FREEDOM

Hungary’s Fundamental Law185 and sectoral legislation provide the legal framework for theprotection of media freedom and pluralism. The Media Act186 regulates, in detail, both the
Hungarian media regulator, as well as the governance of public service media. The Freedomof Information Act establishes a detailed framework which regulates the right to access
178

Input from Hungary for the 2024 Rule of Law report, pp. 11-13. See also Anti-Corruption Task Force (2023),
2022 Report of the Anti-Corruption Task Force, and Corruption Research Center Budapest (2024), Two
Communication Companies in the Hungarian Public Procurement Market 2012-2023.
179
Information received in the context of the country visit to Hungary from Transparency International
Hungary, K-Monitor and Corruption Research Center Budapest. According to the Government, national
legislation does not allow public entities to conclude contracts with or make payments to non-transparent
entities; information on the transparency of such entities is available and beneficial owners are in all cases
identified.
180
Assets of private equity funds have increased from 0.2% in 2020 to 2.3% of GDP in 2023.
181
Corruption Research Center Budapest (2023), The new trends of corruption risks in Hungarian public
procurement (2023). On government communications contracts, see Szabad Európa (2024), Overpricing isonly one of the tricks – this is how Gyula Balásy gets all state orders. Regarding EU-related procurement,
see Integrity Authority (2024), Conclusion of inquiry III_86_2023 – modernisation of cattle farm and theAnnual Analytical Report for 2022 with recommendations for managing authorities. Hungary has committed
to reduce to 15% the high share of calls for tenders that result in a single bid, see RRP, while the share of
single bids is reportedly significantly higher for high-value, non-EU fund-related public procurements. See
also European Commission (2024), The Single Market and Competitiveness Scoreboard on access to public
procurement in Hungary reporting 33% of single bids for 2022.
182
SELDI (2023), Bridges to nowhere – State Capture and Corruption Risks in Fiscal Transfers and Public
Procurement at the Local Level in Southeast Europe, p. 57: when the mayor is from the same political party
as the one forming the ruling coalition on the national level the value of public procurement contracts
increases by approximately 56% in Hungary.
183
Corruption Research Center Budapest (2023), Fourteen Graphs and Two Tables on the New Trends ofCorruption Risk in the Hungarian Public Procurement 2005-2022; Corruption Research Center Budapest(2023), White Elephants in Hungary – Lessons of some EU funded projects. See also Átlátszó (2023), We
identified the companies that have won hundreds of public contracts in a single city.
184
See in this context also European Commission (2024), 2024 Country Report Hungary, p. 4.
185
Article IX(2) of the Fundamental Law.
186
Act CLXXXV of 2010.

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www.parlament.gv.atinformation held by public authorities187. The Press Act188 lays down general andfundamental rules on freedom of the press and media content.
There has been no progress to strengthen the functional independence of the Hungarian
media regulator. The 2023 Rule of Law Report recommended to Hungary to ‘[i]ntroduce
mechanisms to enhance the functional independence of the media regulatory authority taking
into account European standards on the independence of media regulators’189. The decisionmaking body of the Authority, the Media Council, remains composed of members all
nominated by Parliament. The Commission’s action against Hungary in front of the Court ofJustice - in relation to the Media Council’s refusal to renew the broadcasting license of
independent radio station Klubrádió, which resulted in the radio being taken off air - isongoing190. In light of the unresolved concerns with regard to the authority, the 2024 MediaPluralism Monitor (MPM) once more assesses the independence and effectiveness of theMedia Authority as an area presenting high risk, referring to the authority’s composition, lackof transparency of its decision-making process and ‘clear political bias’191. Given that no
measures have been adopted or are planned to strengthen the regulator’s functional
independence, there has been no progress as regards the recommendations made in theprevious years.
There has been no progress to increase transparency and fairness in the distribution ofstate advertising. The 2023 Rule of Law Report recommended to Hungary to ‘adopt
legislation to ensure fair and transparent distribution of advertising expenditure by the stateand state-owned companies’192. No measures have been announced to that effect.
Stakeholders concur that the State is, by far, the most important player in the media
advertising ecosystem and that the channelling of significant state resources to progovernment media continues to prevent a level playing field in the Hungarian media
landscape193. MPM 2024 states that ‘for years now, the government is seen as the largest
advertiser on the Hungarian media market’, continues to consider this to be an area of
medium risk194. Given that no legislative or other measures have been adopted or are plannedby the Government, there has been no progress as regards the recommendations made in theprevious years.
There are no specific rules on transparency in the ownership structure of media
companies. Registers maintained by the media authority contain limited information on
187

Hungary ranks 67th in the 2024 Reporters without Borders World Press Freedom Index compared to 72 nd theprevious year.
188
Act CIV of 2010.
189
2022 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2. In the 2023 Rule of
Law Report, the Commission concluded that no progress had been made on the recommendation (2023 Ruleof Law Report, Country Chapter on the rule of law situation in Hungary, p. 2).
190
Action brought by the Commission on 17 February 2023 in case Commission v Hungary (Case C-92/23).
Klubrádió currently operates online.
191
Media Pluralism Monitor 2024, country report on Hungary, pp. 15-16.
192
2022 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2. In the 2023 Rule of
Law Report, the Commission concluded that no progress had been made on the recommendation (2023 Ruleof Law Report, Country Chapter on the rule of law situation in Hungary, p. 2).
193
Contribution from International Press Institute for the 2024 Rule of Law Report, p. 18; contribution from
Mérték Media Monitor for the 2024 Rule of Law Report, p. 19; contribution from Reporters Without
Borders for the 2024 Rule of Law Report, pp. 16-17.
194Media Pluralism Monitor 2024, country report on Hungary, p. 29.

27

www.parlament.gv.atmedia service providers, but direct ownership information is available via the businessregister. This leads the 2024 MPM to once more consider this a high-risk area although it
points out that ‘in practice […] the public is often aware of the ultimate beneficial owners
behind a particular outlet’ due to the attention which journalists and researchers have given tothis matter195. There has been no change to the Hungarian system of review of market
concentration in the media market and, to date, no attempt by the Media Authority to examine
the impact of major operations on the plurality and diversity of the Hungarian media
market196.
There has been no progress to enhance the independence of public service media. The
2023 Rule of Law Report recommended to Hungary to ‘[s]trengthen the rules andmechanisms to enhance the independent governance and editorial independence of public
service media taking into account European standards on public service media’ 197. No
significant legislative or policy changes have been adopted or are planned in terms of thegovernance and funding of public service media, and concerns in relation to its financial andeditorial independence persist198. As a consequence, the 2024 MPM has maintained its very
high-risk score for this area based on its findings, among others, that public service media isfinancially dependent on the governing majority and the lack of effective control
mechanisms199. There has thus been no progress on the recommendations made in theprevious years200.
Further legislative changes have introduced some restrictions to the freedom of
information which had been subject to a recent reform. The 2023 Rule of Law Report
noted that a recent reform sought to facilitate access to public information and rendered thecharging of fees exceptional. The reform aimed to accelerate litigation in connection withdata of public interest, by introducing very tight procedural deadlines. Stakeholders also
noted that the reform had established the over-arching principle that public information
should be provided free of charge, rendering associated fees exceptional201. Stakeholders
report that the reform has indeed resulted in speeding up litigation in freedom of information
cases in front of the courts, although extraordinary remedies before the Kúria and ineffective
enforcement proceedings significantly delay the release of the documents and data
195

Media Pluralism Monitor 2024, country report on Hungary, pp. 19-20.
See 2020, 2021 and 2022 Rule of Law Reports, Country Chapters on the rule of law situation in Hungary. An
overview of the media market, including main players and trends, can be found in the 2023 Media Market
Report prepared by the Media Authority. National Media and Infocommunications Authority (2023), Media
Market Report 2023.
197
2022 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2. In the 2023 Rule of
Law Report, the Commission concluded that no progress had been made on the recommendation (2023 Ruleof Law Report, Country Chapter on the rule of law situation in Hungary, p. 2).
198
For details with regard to the legislative framework regulating public service media see 2022 Rule of Law
Report, Country Chapter on the rule of law situation in Hungary, pp. 22-23.
199
Media Pluralism Monitor 2024, country report on Hungary, pp. 29-30.
200
According to the European Parliament’s Flash Eurobarometer: News & Media Survey 2023, 25% of
respondents in Hungary stated that they trust public TV and radio stations, below the EU average of 48%.
2012023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 28. Stakeholders pointout that under the new rules, the defendant may present its defence (the reasons for rejecting the access to
documents application) orally at the first court hearing; in such a situation, the data requester cannot prepare
effectively and has to develop its arguments right during the first hearing. Courts have adequate resources toprocess freedom of information cases within the statutory deadlines (information received in the context ofthe country visit to Hungary from the National Office for the Judiciary).
196

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requested202. In 2023 and 2024, Parliament adopted further legislative amendments,
introducing new grounds for rejecting freedom of information requests203. Furthermore, in
direct response to a court decision which had ordered access to certain unclassified but
unpublished government documents, as of 1 March 2024 a legislative amendment204
expressly allowed the authorities to limit public access to this category of documents.
According to stakeholders, these amendments make access to public information moredifficult205. Parliament has so far not implemented a Constitutional Court decision206
requiring legislative amendments to establish effective judicial protection in case of freedomof information requests related to public funds, addressed to the recipients of such funds.
While Hungary committed207 to ensure that all public bodies publish specified data on the
new transparency portal, stakeholders point out that proactive data publication on the new
portal is not mandatory for all entities performing a public duty and certain features of theportal hamper its usefulness in accessing data208. The MPM 2024 maintains its high-risk
score for this area209.

202

Joint contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law
Report, pp. 64-65; contribution from Hungarian Civil Liberties Union for the 2024 Rule of Law Report, p.
20. The Kúria has 60 days to rule on a petition for review limited to points of law (Section 31/C(5) of Act
CXII of 2011); this procedural deadline cannot be extended.
203
Act CI of 2023 amended Act CXXII of 2009 and Act CXII of 2011. As of 30 December 2023, the new
Section 3/A of Act CXXII of 2009 obliged State-owned companies to deny for a period of 10 years,
following advice from a Minister, the freedom of information requests related to their foreign investments
and foreign relations. As of 1 January 2024, the new Section 30(2a) of Act CXII of 2011 provides that public
service entities may deny a freedom of information request if granting it would require the collection of datafrom another public service entity or would require the production of new data by comparing data inpossession of the two entities. According to the Government, this amendment was necessary in order to meetthe requirements set out both by the Kúria and the Constitutional Court (written contribution from theauthorities in the context of the country visit to Hungary).
204
The new Section 7/A of Act CXXV of 2018 on Government administration introduced by Act CIX of 2023.
On 16 March 2023, the Budapest Regional Court (15.P.22.010/2022/15), confirmed on appeal by the
Budapest Regional Appeal Court (Pf.20236/2023/5) on 13 June 2023, ordered the Government to grant news
portal hvg.hu access to unclassified but unpublished Government decisions. The new provision allows theauthorities to refuse public access to such unclassified documents for a period of 20 years maximum to‘safeguard the public interest’.
205
Joint contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law
Report, p. 64; contribution from Transparency International Hungary for the 2024 Rule of Law Report, p. 13.
206
Decision 7/2020. (V. 13.) AB concerned a freedom of information request addressed to a private company(not an entity performing a public duty) related to the construction of a motorway financed from EU funds.
207
Hungary committed to ensure that all public bodies proactively publish a predefined set of information on
the use of public funds in a central register in an open, interoperable and machine-readable format, whichallows bulk download and data to be sorted, searched, extracted, compared and reused; access to the data
shall be provided free of any charge and without the need to register (RRP milestones 175, 176).
208
K-Monitor (2023), Report on the Access to Information, pp. 5-9. The new Central Public Data Information
Register is an online repository where certain public entities upload metadata on their contracts (not thecontracts themselves). The National Data Protection and Freedom of Information Authority has launched‘transparency procedures’ in case of non-compliance; these procedures focused on data that had already been
made public in the Electronic Public Procurement System. The Register does not allow search by the nameof companies that were awarded the contracts. While data are accessible and downloadable in CSV and PDF
formats, bulk access to data is prevented by ‘captchas’. The Register has a limited personal scope comparedto the already existing but not widely used public data site (kozadat.hu) because it exempts several entities
performing a public duty (‘közfeladatot ellátó szerv’). Only public entities having a budgetary status(‘költségvetési szerv’) under Act CXCV of 2011 fall under the scope of the new disclosure rules (Section
37/C of Act CXII of 2011). Municipalities, municipality-owned companies, public interest trusts (e.g.
Mathias Corvinus Collegium), State-owned companies (e.g. Hungarian National Asset Management Inc.,29

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Journalists and other media professionals continue to face numerous challenges.
Following an amendment to the Criminal Code210, slanderous or defamatory statements madein the press or in the media as part of the public discourse are no longer punishable, unlessthey ‘are aimed at a manifest and seriously offensive denial of the human dignity of theaggrieved party’. While stakeholders point out that physical attacks against journalists arevery rare in Hungary, they continue to draw attention to the selective access to government
premises and events, as well as the prevalence of seemingly coordinated smear and delegitimisation campaigns against various journalists who are frequently labelled ‘foreign
agents’, ‘mercenaries’ and ‘traitors’211. The 2024 MPM continues to consider the safety ofjournalists to be an area of medium risk212. The 2023 Mapping Media Freedom monitoring
report flags the targeting of numerous media outlets by Distributed Denial-of-Service (DDoS)
cyberattacks as a new emerging threat213. The Council of Europe’s Platform to promote theprotection of journalism and safety of journalists registered two new alerts relating to,respectively, the adoption of the Protection of National Sovereignty Act214 and DDoS
attacks215.
IV.

OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES

Hungary is a parliamentary republic with a unicameral Parliament (National Assembly).
Parliament, among other functions, adopts and amends the Fundamental Law of Hungary,legislates, including cardinal laws216, elects the Prime Minister, and elects – by a two-thirds
majority – the top rank public officials of the country. The President of the Republic iselected by Parliament. There are a number of institutions tasked with counter-balancing thepowers of the legislature and the executive, and are entrusted with guaranteeing the respect of
the constitutional order, including the Constitutional Court, the State Audit Office and the
Ombudsperson (‘Commissioner for Fundamental Rights’); the latter is also tasked with theroles of the equality body and national human rights institution. The Constitutional Court
reviews the constitutionality of laws and judicial decisions. In addition to the Government,
the President of the Republic, every parliamentary committee and any member of Parliament
may table a draft law.
Increasing state interventions and arbitrary decisions of the authorities weaken legal
certainty and remain a problem for the operation of businesses in the single market. The
Hungarian Tourism Agency, Bethlen Gábor Fund Management Inc.) and the Hungarian National Bank are
not required to provide data to the new Register. The entities falling outside the scope of the new rules arestill obliged to publish data in accordance with the ‘general disclosure list’ (Annex 1 to Act CXII of 2011)
but non-compliance is not sanctioned.
209
Media Pluralism Monitor 2024, country report on Hungary, p. 14.
210
Sections 226(3) and 227(3) of Act C of 2012, amended by Act XXX of 2023 as of 2 June 2023.
211
Contribution from International Press Institute for the 2024 Rule of Law Report, p. 20; contribution from
Reporters Without Borders for the 2024 Rule of Law Report, p. 18. See also Human Rights Watch (2024), ‘I
Can’t Do My Job as a Journalist’ – The Systematic Undermining of Media Freedom in Hungary, p. 24-25.
212
Media Pluralism Monitor 2024, country report on Hungary, pp. 14-15.
213
Media Freedom Rapid Response (2023), Mapping Media Freedom - Monitoring Report 2023, p. 28.
214
See pillar IV.
215
Council of Europe, Platform to promote the protection of journalism and safety of journalists.
216
The Fundamental Law provides for the adoption of 36 cardinal laws containing detailed rules on thefunctioning of key institutions. They may be adopted or amended by a two-thirds majority of the members of
Parliament present. The Venice Commission has been critical of Hungary for using cardinal acts beyond
what is strictly necessarywhich has been considered questionable from a democratic perspective as it makes
it difficult to introduce reforms in the future (CDL-AD(2012)009, para. 47).

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2023 Rule of Law Report noted that the Government continued to use its emergency powers
extensively, which undermines legal certainty and affects the operation of businesses in the
single market217. The Government extended until November 2024 the ‘state of danger’
declared by the Government on 25 May 2022 ‘in view of the armed conflict and humanitariancatastrophe in Ukraine and with a view to averting their impact on Hungary’ 218. In this way,
the Government can override Acts of Parliament. Several emergency measures adopted in thereporting period might have an impact on the business environment219, while others do notseem to be related to the ‘state of danger’220. Parliamentary oversight of individual
emergency measures is weak221. Stakeholders reported that the Constitutional Court cannot
ensure the effective and timely review of emergency measures222 and that the extensive andprolonged use of the Government’s emergency powers has undermined legal certainty223. The
Government has continued to declare certain investment projects to be of ‘strategic
importance for the national economy’ or of ‘priority’. While the Government maintains thatlegal remedies before the ordinary courts exist, these types of projects are exempt from public
oversight and control224 merely through decrees, which can only be challenged before the2172023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 31.
Government Decrees 167/2023 of 11 May 2023, 515/2023 of 22 November 2023 and 86/2024 of 17 April
2024 amended Government Decree 424/2022 of 28 October 2022 by extending the ‘state of danger’ until 26
November 2023, 24 May and 19 November 2024, respectively. The Government needed an authorisationfrom Parliament to extend the ‘state of danger’. This authorisation was given through Section 2(1) of Act
XLII of 2022, as amended by Act XI of 2023, Act LXXII of 2023 and Act VIII of 2024. In parallel, Hungary
has been under a ‘crisis situation caused by mass immigration’ since 10 March 2016.
219
E.g. in the second half of 2023, the rules applicable to insolvency and winding up have been amended
several times through Government Decrees: 265/2023 of 28 June 2023, 267/2023 of 29 June 2023, 335/2023
of 20 July 2023, 436/2023 and 437/2023 of 21 September. Also, Government Decree 279/2023 of 29 June
2023 increased from 10 to 15 % the discount retailers are forced to offer on certain food products. In 2023,
the Government adopted 119 emergency measures; some emergency measures were subsequently
incorporated in statute (information received in the context of the country visit to Hungary from the National
Assembly). The Commission has brought infringement procedures against certain emergency measuresconsidered incompatible with EU law (e.g. INFR(2021)2158, INFR(2022)4009, INFR(2022)4108).
According to the Government, some emergency measures were adopted in the reporting period in order toprotect vulnerable social groups and economic segments.
220
For instance, Government Decree 523/2023 of 30 November 2023 removes the protection granted to listedbuildings and local heritage requirements established by local municipalities in the case of certain
investments of strategic importance for the national economy. The apparent objective is to facilitate thebuilding of a new university campus in the 8th District of Budapest without the consent of the local
authorities (contribution from Hungarian Helsinki Committee for the 2024 Rule of Law Report, p. 38).
221
Contribution from Democracy Reporting International for the 2024 Rule of Law Report, p. 5. The
Government needs to keep Parliament informed about the decrees adopted during the ‘state of danger’;
Parliament may repeal such Government decrees (Article 53 of the Fundamental Law); the Government has
to take all measures necessary to guarantee the continuous functioning of Parliament and the Constitutional
Court (see Article 52 of the Fundamental Law). Parliament has no ex ante control over individual emergency
measures.
222
Joint contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law
Report, p. 74; contribution from Eötvös Károly Policy Institute for the 2024 Rule of Law Report, p. 38.
223
Contribution from Council of Bars and Law Societies of Europe for the 2024 Rule of Law Report, p. 68.
224
The Government has issued Decrees under Act LIII of 2006 (replaced, as of 1 January 2024, by Act C of2023 on Hungarian architecture). See 2023 Rule of Law Report, Country Chapter on the rule of law situationin Hungary, p. 32. Such measures include Government Decree 220/2023 of 1 June 2023 (two ports on Lake
Balaton), Government Decree 263/2023 of 28 June 2023 (smart logistics park), Government Decree373/2023 of 7 August 2023 (primary school), Government Decree 390/2023 of 14 August 2023 (technologypark), Government Decree 418/2023 of 31 August 2023 (building material factory), Government Decree423/2023 of 5 September 2023 (worker hostel next to an economic zone), Government Decree 429/2023 of
14 September 2023 (bank building, hotel development), Government Decree 483/2023 of 31 October 2023
218

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Constitutional Court. So far, the Court has not annulled any of these Decrees 225. On 19 June
2024, in the context of the European Semester, the Commission proposed that the Council
recommend that Hungary ‘[i]mprove the regulatory framework and enhance competition in
product markets and services by avoiding arbitrary administrative interventions and theselective use of tailor-made legislation providing undue advantage or disadvantage to specificcompanies, by applying competition scrutiny systematically to business transactions and by
reducing the use of emergency measures to what is strictly necessary, in line with theprinciples of the single market and the rule of law’226.
The quality of law-making and the frequent changes in legislation remain a significant
cause for concern. Stakeholders reported that while draft pieces of legislation are publishedon the Government’s website, response times are limited to the statutory eight days and there
is no meaningful feedback227. Stakeholders also note that important legislative changes are
not subject to public consultation or a meaningful debate in Parliament because of theGovernment’s practice to include only technical amendments in draft laws and then,following a purely formal process, introduce new provisions in the bill through theCommittee on Legislation228 just before the final vote in Parliament229. The quality of law-(new production hall and office), Government Decree 495/2023 of 2 November 2023 (industrial park),
Government Decree 502/2023 of 13 November 2023 (industrial and logistics park), Government Decree555/2023 of 12 December 2023 (apartment building), Government Decree 577/2023 of 18 December 2023
(university campus), Government Decree 671/2023 of 29 December 2023 (shooting range), Government
Decree 10/2024 of 25 January 2024 (truck parking and logistics centre).
225
The Constitutional Court has dismissed the constitutional complaints challenging Government Decrees
384/2016 of 2 December 2016 and 141/2018 of 27 July 2018 (Decision 3441/2022. (X. 28.) AB and case
II/02785/2023). The Constitutional Court has rejected the constitutional complaints challenging Government
Decree 141/2018 of 27 July 2018 (Orders 3264/2021. (VII. 7.) AB, 3299/2021. (VII. 22.) AB and
3300/2021. (VII. 22.) AB), Government Decree 523/2021 of 6 September 2021 (3454/2022. (X. 28.) AB)
and Government Decree 314/2022 of 11 August 2022 (Order 3087/2024. (III. 1.) AB). On 17 July 2024, theConstitutional Court found that a provision of Government Decree 6/2022 of 14 January 2022, repealed as of
1 August 2023, had been unconstitutional; it dismissed the remainder of the complaint.
226
COM(2024) 617 final. The Commission has launched several investigations and infringement procedures
against Hungary, many concerning legislation in fields defined by the Hungarian Government as having
strategic interest. For instance, the Commission has recently referred Hungary to the Court of Justice of the
EU in two cases concerning restrictive Hungarian measures in the construction sector (cases C-499/23 andC-144/24) and is actively pursuing cases in other sectors, including public procurement and motorway
concessions. Commission services are also closely monitoring the situation in the retail sector and arecarrying out investigations with regard to potential violations of EU law in this area. A pattern of instanceswhere companies from elsewhere in the EU are effectively hindered in their economic activities in anotherMember State would constitute a major threat to the Single Market.
227
Joint contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law
Report, p. 91. The Hungarian Chamber of Commerce and Industry – a public body set up by law – hasentered into a strategic cooperation with the Government and several Ministries and it has the opportunity tocomment on draft legislation (information received in the context of the country visit to Hungary from the
Hungarian Chamber of Commerce and Industry).
228
The Committee on Legislation is a special committee whose activities are specifically related to thelegislative functions of the National Assembly; it is chaired by the Deputy Speaker. As a rule, the Committee
intervenes following the end of the detailed debate in plenary (Section 46(2) of the Rules of Procedure).
229
Joint contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law
Report, p. 70; contribution from Eötvös Károly Policy Institute for the 2024 Rule of Law Report, p. 36.

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making and the frequent changes in legislation remain a significant cause for concern about
the effectiveness of investment protection among companies in Hungary230.
Concerns regarding the independence and effective functioning of the Commissioner for
Fundamental Rights remain. The UN Sub-Committee on Accreditation (SCA) of the
Global Alliance of NHRIs (GANHRI) has not revised its earlier recommendation that the
Hungarian national human rights institution be downgraded to B-status231. Stakeholders
reported that the deficiencies pointed out by the SCA persist232. In December 2023, theDeputy Commissioner organised a conference on vulnerable groups in the courtroom, with a
special focus on children and refugees233. The mandate of the Commissioner was
significantly extended in 2023 with regard to the protection of persons with disabilities234, as
well as whistleblower protection235. According to stakeholders, the trend236 to merge all
specialised human right protection institutions into the Commissioner’s Office could behighly problematic due to not only the lack of functional independence of the Office, but also
due to the decreased institutional focus and resources in an organisation with multiple
mandates237. In that context, the Government refers to the Paris Principles238 that require that230

23% of the surveyed companies perceive the frequent changes in legislation or concerns about quality oflaw-making process as a reason for the lack of confidence in investment protection (Figure 56, 2024 EU
Justice Scoreboard).
231
The SCA found that the Commissioner for Fundamental Rights ‘has not effectively engaged on […] all
human rights issues, including in relation to vulnerable groups such as ethnic minorities, LGBTI, refugees
and migrants as well as constitutional court cases deemed political and institutional, media pluralism, civic
space and judicial independence (2022 Rule of Law Report, Country Chapter on the rule of law situation in
Hungary, p. 27).
232
Contribution from Hungarian Helsinki Committee for the 2024 Rule of Law Report, p. 40, joint contribution
from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law Report, pp. 78-79.
According to stakeholders, the rules of the selection and appointment process have not been amended, andrespective concerns have not been addressed. The publicly available information on the Commissioner’s
work evidences that it still does not effectively promote and protect all human rights and vulnerable groups.
The Commissioner did not issue any public reports that dealt with the rights of LGBTIQ people or refugees
and migrants, despite the wide-ranging rights violations suffered by these groups in Hungary, and did not
focus in any of its public reports on the situation of human rights defenders, media pluralism or judicial
independence either. According to the Government, the Commissioner is independent in his or her actions,subject only to the law, and cannot be instructed in connection with his or her activities.
233
In addition, in June and October 2023 and February, April and June 2024, the Commissioner participated atconferences about children’s rights, equal treatment, sustainable development, national minorities and therole of ombudspersons.
234
As of 1 January 2023, the Commissioner has assumed the responsibilities of the independent mechanism
defined in the UN Convention on the Rights of Persons with Disabilities (see 2023 Rule of Law Report,
Country Chapter on the rule of law situation in Hungary, p. 33). The Commissioner has set up a Disability
Advisory Board for the close cooperation with CSOs and the performance of his tasks related to the
independent disability mechanism (input from Hungary for the 2024 Rule of Law Report, p. 21).
235
Input from Hungary for the 2024 Rule of Law Report, p. 21. Act XXV of 2023 on complaints, disclosures inof public interest and related rules on reporting abuses entered into force on 24 July 2023. The system run by
the Commissioner’s Office is meant to be the external reporting channel as defined in Directive (EU)2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons
who report breaches of Union law (the ‘Whistleblowing Directive’).
236
Since 2015, the Commissioner has been tasked with the role of National Preventive Mechanism under the
Optional Protocol to the UN Convention against Torture and other Cruel, Inhuman or Degrading Treatment
or Punishment. In 2020, the Commissioner took over the responsibilities of the Independent Police
Complaints Board. In 2021, the Equal Treatment Authority was merged into the Commissioner’s Office.
237
Contribution from Hungarian Helsinki Committee for the 2024 Rule of Law Report, pp. 40-41.
238
Principles relating to the Status of National Institutions, adopted by the UN General Assembly on 20
December 1993.

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national institutions possess the widest possible mandate to promote and protect humanrights.
New rules rendered the judicial review of administrative decisions more difficult. As of
1 January 2024, a public authority may amend or repeal its administrative decision after
receiving an application seeking judicial review but before transmitting the file to thecourt239. If the citizen or a business fails to contest the amended decision within eight days,
the application for review becomes ineffective, and the authority is not obliged to transmit thefile to the court. According to stakeholders240, these new rules, and in particular the tightdeadline, is a disincentive for citizens and businesses to seek judicial review, which raises
issues under European standards241..Also, the Court of Justice of the EU has found thatnational law preventing third-country nationals who, on the basis of confidential information
obtained by the Constitution Protection Office, have had their residence permit withdrawn, or
have been refused such a permit, from being informed even of the substance of the grounds
forming the basis of those decisions and from using such information for the purposes of an
administrative procedure or judicial proceedings violates EU law242.
Concerns persist due to the absence of effective judicial or other oversight as regards
the use of secret surveillance measures outside criminal proceedings. The 2023 Rule of
Law Report noted that ‘[f]urther concerns [had] been raised due to the absence of effective
oversight as regards the use of secret surveillance measures outside criminal proceedings’243.
No steps have been taken to address these concerns. Stakeholders note that the excessively
broad range of potential victims of surveillance may give rise to mass-surveillance244. On 13
June 2024, the Council of Europe’s Committee of Ministers ‘strongly exhorted the authorities
to adopt, without further delay, the measures required to bring the domestic legislation on
secret surveillance for national security purposes fully and effectively in line with theConvention requirements’245. Previous reports highlighted that journalists and other media
professionals have been targeted by spyware246. In spite of subsequent investigations into the239

Section 115(5) and (6) of Act CL of 2016 on general rules of administrative procedure and Section 83(7) and(6) of Act I of 2017 on the code of administrative litigation. Before this legislative amendment, the citizen or
business could amend the application before the court within a fair and reasonable time limit (30 days). Afterthe legislative amendment, the citizen or business is bound by a strict 8-day time limit before the file reaches
the court. If the public authority decides not to file a defence with the court, it can amend its administrativedecision to the detriment of the citizen or business (e.g. by increasing the amount of the administrative fine)at any point of time until the file is transmitted to the court or even until the end of the court proceedings.
240
Contribution from Magistrats Européens pour la Démocratie et Libertés (MEDEL) for the 2024 Rule of Law
Report, pp. 23-24; contribution from Res Iudicata Association for the 2024 Rule of Law Report, pp. 22-23.
The Hungarian Chamber of Commerce and Industry has not registered any questions, comments orcomplaints from its members as regards the judicial review of administrative decision (information received
in the context of the country visit to Hungary from the Hungarian Chamber of Commerce and Industry).
241
Judgments of the European Court of Human Rights of 27 February 1980, Deweer v Belgium, 6903/75 and of
9 November 2004, Marpa Zeeland B.V and Metal Welding B.V. v Netherlands, 46300/99.
242
See for EU law requirements judgment of the Court of Justice of 25 April 2024, NW and PQ, C- 420/22 andC- 528/22, ECLI:EU:C:2024:344, para. 101.
243
See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 33. The executionof judgments of the European Court of Human Rights of 12 January 2016, Szabó and Vissy v Hungary,
37138/14 and of 29 September 2022, Hüttl v Hungary, 58032/16 is pending.
244
Joint contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law
Report, p. 61.
245
CM/Del/Dec(2024)1501/H46-17.
246
For details, see 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 29.

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matter, there were no consequences for individuals or entities concerned, nor were any
legislative changes initiated247. In February 2024, Hungary signed with China a memorandumof understanding on performing joint patrolling services which allows Chinese police tooperate on the territory of Hungary248.
The Constitutional Court still reviews the merits of final rulings of ordinary courts inpolitically sensitive cases. The 2023 Rule of Law Report noted that legal certainty had been
improved as public authorities could no longer challenge final judicial decisions before theConstitutional Court249. The Constitutional Court, composed of members elected by
Parliament without the involvement of the judiciary, is still reviewing judgments of theordinary courts acting as ‘a court of fourth instance’250. In several such cases, some of them
politically sensitive, final judgments of the ordinary courts were annulled251. Stakeholders
noted that the Constitutional Court does not have a case allocation scheme and cases are
assigned to judges-rapporteurs under non-transparent rules252. Moreover, although the law
requires that the Constitutional Court render a decision on a constitutional complaint within areasonable time, stakeholders noted that the Constitutional Court is not bound by procedural
deadlines when hearing such cases253. As a rule, this domestic remedy needs to be exhausted
before filing an application with the European Court of Human Rights254. As of 14 DecemberFriedrich Naumann Foundation and International Press Institute (2024), Watching the Watchdogs – Spyware
surveillance of journalists in Europe and the ongoing fight for accountability, pp. 12-14.
248
Reuters (2024), In unusual move, China offers to back Hungary in security matters. The text of theagreement is not public.
249
On 13 December 2023, the Commission positively assessed this legislative amendment under Article 15 of
the Common Provisions Regulation.
250
2022 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, pp. 27-28. Normally, theConstitutional Court reviews the constitutionality of judicial decisions and annuls them only if they violate
fundamental rights. However, in certain cases the Constitutional Court qualifies the contra legeminterpretation of the law by ordinary courts as a breach of the right to a fair trial, allowing the Constitutional
Court to assess the merits of the case (see Decision 20/2017. (VII. 18.) AB, paragraphs 23-30; Decision
23/2018. (XII. 28.) AB, paragraphs 26-30).
251
Joint contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law
Report, p. 23. On 9 May 2023, the Constitutional Court annulled a Kúria judgment that had dismissed theapplication of a mayor from the governing party brought against his political opponent because of libel(Decision 3234/2023. (VI. 2.) AB); on 11 July 2023, the Constitutional Court annulled a judgment of theGyőr Regional Court that had allowed a local referendum concerning the expansion of the Győr industrial
zone (Decision 16/2023. (VII. 25.) AB); on 19 July 2023, the Constitutional Court annulled two Kúria
judgments that had allowed a national referendum on questions concerning public education (Decisions
20/2023. (VIII. 7.) AB and 21/2023. (VIII. 7.) AB); on 19 December 2023, the Constitutional Court annulleda Kúria judgment that had dismissed the application of a public interest trust headed by the Prime Minister’s
political director brought against an opposition party for libel (2/2024. (I. 9.) AB); on 9 January 2024, theConstitutional Court annulled two Kúria judgments that had allowed a national referendum on questions
concerning public education (Decisions 3/2024. (I. 25.) AB and 4/2024. (I. 25.) AB); on 5 July 2024, theConstitutional Court annulled a Kúria decision confirming the election of the opposition candidate for thepost of mayor of Budapest (case IV/02641/2024).
252
Joint contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law
Report, p. 12.
253
Joint contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law
Report, p. 23. For instance, on 9 May 2023, the Constitutional Court dismissed a constitutional complaint,
filed on 26 June 2013, challenging an individual judgment in a freedom of information case (Decision3233/2023. (VI. 2.) AB).
254
Decision of the European Court of Human Rights of 19 June 2018, Mendrei v. Hungary, 54927/15, of 12
March 2019, Szalontay v Hungary, 71327/13, and of 4 June 2019, Karsai v Hungary, 22172/14.
247

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2023, an omnibus law255 inserted a new provision in the Constitutional Court Act256 allowing
the Constitutional Court to give an advisory opinion – upon request of the Court of Justice of
the EU257 – on the interpretation of the rules related to Hungary’s constitutional order,
constitutional requirements, constitutional traditions, national identity, sovereignty,
population, and rights and freedoms enshrined in the Fundamental Law.
On 1 January 2024, Hungary had 45 leading judgments of the European Court of
Human Rights pending implementation, an increase of two compared to the previous
year258. Hungary’s rate of leading judgments from the past 10 years that remain pending is at
76% (compared to 71% in 2023), which remains the highest in the EU, and the average timethat the judgments have been pending implementation is over 6 years and 2 months(compared to over 6 years and 8 months in 2023)259. The oldest leading judgment, pending
implementation for almost 15 years, concerns the violation of the right to freedom ofassembly260. As regards the respect of payment deadlines, on 31 December 2023 there were
47 cases in total awaiting confirmation of payments (compared to 82 in 2022)261. On 1 July
2024, the number of leading judgments pending implementation had had increased to 47262.
The execution of the judgments of the European Court of Human Rights in the Kenedi v
Hungary263 and Magyar Helsinki Bizottság v Hungary264 cases is still pending. Hungary also
faces challenges as regards the effective implementation of judgments of the Court of Justiceof the EU265.

255

Act LXXXV of 2023.
Section 38/A of Act CLI of 2011 on the Constitutional Court.
257
EU law does not provide for such a request by the Court of Justice of the EU.
258
The adoption of necessary execution measures for a judgment by the European Court of Human Rights issupervised by the Council of Europe’s Committee of Ministers. It is the Committee’s practice to group cases
against a State requiring similar execution measures, particularly general measures, and examine themjointly. The first case in the group is designated as the leading case as regards the supervision of the generalmeasures and repetitive cases within the group can be closed when it is assessed that all possible individual
measures needed to provide redress to the applicant have been taken. According to the Government, it
always cooperates with the Committee of Ministers, however often complex measures need to be taken to
execute the judgments.
259
All figures are calculated by the European Implementation Network and are based on the number of casesthat are considered pending at the annual cut-off date of 1 January 2024. See the Contribution from theEuropean Implementation Network for the 2024 Rule of Law Report, p. 5.
260
Judgment of the European Court of Human Rights of 7 October 2008, Patyi and Others v Hungary, 5529/05,
pending implementation since 2009.
261
Council of Europe (2024), Supervision of the execution of judgments decisions of the European Court of
Human Rights – 17th Annual Report of the Committee of Ministers – 2023, p. 137.
262
Data according to the online database of the Council of Europe (HUDOC).
263
Judgment of the European Court of Human Rights of 26 May 2009, Kenedi v Hungary, 31475/05. The Court
found the violation of the applicant’s right to freedom of expression on account of the continued resistanceof the authorities to grant him access to documents concerning the Hungarian secret services for the purposeof historical research and the lack of an effective remedy in this respect.
264
Judgment of the European Court of Human Rights of 8 November 2016, Magyar Helsinki Bizottság v
Hungary, 18030/11. The Court found the violation of the applicant’s freedom to receive information on
account of the authorities’ refusal, in 2009, to provide it with the names of public defenders and the numberof their appointments for a survey on the efficiency of the public defenders system.
265
On 24 April 2024, the Commission called on Hungary to fully comply with the ruling of the Court of Justicein case C-66/18 and decided to send a letter of formal notice to that end. Also on 24 April 2024, theCommission decided to send a letter of formal notice to Hungary for failing to comply with the ruling of the
Court of Justice in case C-823/21. In another case, on 13 June 2024, the Court of Justice found that Hungary
had failed to take all the necessary measures to comply with the judgment delivered by the Court on 17
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There has been no progress in removing existing obstacles affecting civil society
organisations, while new legislation further undermined civic space. The 2023 Rule of
Law Report recommended to Hungary to ‘[f]oster a safe and enabling civic space and remove
obstacles affecting civil society organisations, including by repealing legislation that hampers
their capacity of working, in particular the immigration tax’266. While the overall legal
framework for CSOs267 did not change in 2023 and is generally in line with European
standards268, the space for civil society continues to be rated as ‘obstructed’269. Stakeholders
reported that government-coordinated smear campaigns and vilification of independent CSOs
remain a current practice270. The implementation of the law271, adopted in 2021 to repeal theTransparency Act272 in line with the judgment of the Court of Justice273, is pending274. The
so-called ‘child-protection law’275, amending, among others, the law on national public
education276, authorises the responsible minister to regulate by decree the conditions ofregistration for CSOs that are allowed to give sex education classes in public education
institutions. No such decree has been issued ever since, thereby limiting the activity of the
CSOs concerned277. As of 1 January 2023, in response to a judgment of the Court ofDecember 2020 in Case C-808/18; according to the Court of Justice, that failure, which consists indeliberately avoiding the application of a common EU policy as a whole, constitutes an unprecedented andextremely serious infringement of EU law.
266
2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2. In 2023, theCommission registered ‘[n]o progress on removing obstacles affecting civil society organisations’. See also2022 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2.
267
Including Act V of 2013 on the Civil Code and Act CLXV of 2011 on the Freedom of Association, Public
Benefit Status and the Operation and Financing of Civil Society Organisations.
268
Joint contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law
Report, p. 86.
269
Rating by CIVICUS; ratings are on a five-category scale defined as: open, narrowed, obstructed, repressedand closed.
270
Joint contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law
Report, p. 69; contribution from Human Rights Watch for the 2024 Rule of Law Report, p. 20.
271
Act XLIX of 2021; an application seeking the review of the law is pending before the Constitutional Court(Case IV/05049/2021).
272
Act LXXVI of 2017 on the transparency of organisations which receive support from abroad.
273
Judgment of the Court of Justice of 18 June 2020, Commission v Hungary (Transparency of associations),
C-78/18, ECLI:EU:C:2020:476.
274
Under the new rules, in May 2022, the State Audit Office carried out legality checks on all accounts of CSOs
with an annual balance sheet exceeding a certain amount and, therefore, considered capable of influencing
public life. The Summary Report published by the State Audit Office on 2 December 2022 announced thatthe rules governing both the selection criteria and the methodology for the assessment would be reviewed.
The audit of the financial management of CSOs is included in the 2024 audit plan of the State Audit Office(information received in the context of the country visit to Hungary from the State Audit Office).
275
Act LXXIX of 2021 on stricter action against paedophile offenders and amending certain acts for theprotection of children lays down a number of restrictive and discriminatory measures; in particular, it
prohibits or limits access to content that propagates or portrays the so-called ‘divergence from self-identity
corresponding to sex at birth, sex change or homosexuality’ for individuals under the age of 18. The
Commission considered that the law violates the internal market rules, the fundamental rights of individuals(in particular LGBTIQ people) as well as - with regard to those fundamental rights - the EU values; on 15
July 2022, the Commission decided to refer Hungary to the Court of Justice (case C-769/22, pending).
276
Act CXC of 2011 on national public education.
277
2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 36. The Media
Authority, relying on the so-called ‘child-protection law’, decided that the official campaign video of the
28th Budapest Pride festival may be aired by a commercial TV channel between 10 p.m. and 5 a.m only
(Decision 496/2023 of 4 July 2023).

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Justice278, Hungary amended its legislation which criminalised the organisation of activities
carried out with a view to assisting the initiation of applications for international protectionthat do not fulfil the national criteria for granting that protection. Another law279 introducing a
special 25% immigration tax applicable to financial support received by organisations
carrying out ‘activities facilitating immigration’, which also raised concerns, continues toapply, although it is not enforced in practice280. On 12 December 2023, Parliament adopted
the Protection of National Sovereignty Act281; it establishes a new office with broadly definedcompetences tasked with reporting on any person or organisation suspected of serving foreigninterests and/or receiving foreign funding. Independent media outlets issued a statement
warning that the new law is ‘capable of severely restricting the freedom of the press’ 282. In
June 2024, the new office launched investigations into the activities and funding of an anticorruption CSO and an investigative media outlet283. The new law also amended the politicalparty and campaign finance rules without public consultation. Therefore, there has been no
progress on the recommendation made in the 2023 Rule of Law Report.
Concerns related to the State’s role in financing civil society persist. Overall, 40% of civilsociety’s resources come from public funding284. Stakeholders report that this income isdistributed unevenly285, and that the operation of state funding for CSOs is non-transparent286.
278

The Court of Justice has held that Section 353/A of Act C of 2012, introduced by Section 11(1) of Act VI of2018 (part of the so-called ‘Stop Soros’ legislative package) breached Union law, see judgment of the Courtof Justice of 16 November 2021, Commission v Hungary (Incrimination de l’aide aux demandeurs d’asile),
C-821/19, ECLI:EU:C:2021:930.
279
Section 253 of Act XLI of 2018.
280
Joint contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law
Report, p. 69.
281
Act LXXXVIII of 2023 on the protection of national sovereignty. On 7 February 2024, the Commission
decided to launch infringement proceedings against Hungary; on 23 May 2024, the Commission sent a
reasoned opinion. On 18 March 2024, the Venice Commission concluded that the Act has established a new
body with extremely broad competences which can interfere with the privacy of any legal or natural entityand engage in naming and shaming of this entity without being subject to any control or review mechanism;it risks having a chilling effect on the free and democratic discussion in the Hungarian society; the regulation
related to the establishment of the Sovereignty Protection Office and its mandate and competencies is at odds
with international standards and should be repealed (Venice Commission, CDL(2024)002, para. 65).
282
Contribution from International Press Institute for the 2024 Rule of Law Report, p. 16; contribution from
Mérték Media Monitor for the 2024 Rule of Law Report, p. 21; contribution from Reporters Without
Borders for the 2024 Rule of Law Report, p. 17. See also Friedrich Naumann Foundation and International
Press Institute (2024), Watching the Watchdogs – Spyware surveillance of journalists in Europe and theongoing fight for accountability, p. 14.
283
Telex (2024), Transparency International and Átlátszó became the first targets of the Sovereignty Protection
Office; Transparency International Hungary (2024), Press statement: Hungary’s Sovereignty Protection
Office targets Transparency International Hungary with investigation.
284
The total income of associations and foundations in 2022 was HUF 1 270 billion (EUR 3.2 billion), morethan the year before (HUF 1 070 billion; EUR 2.7 billion). Of this, some 40% came from public funding,
25% from private sources, with the rest originating from generated own income and a variety of othersources (joint contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of
Law Report, p. 89).
285
68.5% of the CSOs work with an annual budget of not more than HUF 5 million (EUR 12 644), and only 8%
have income larger than HUF 50 million (EUR 126 444), with the average per organisation being aroundHUF 25 million (EUR 63 222). Independent organisations promoting human rights and similar issues andindependent theatres rarely are able to secure public funding (joint contribution from Amnesty International
Hungary and eight other CSOs for the 2024 Rule of Law Report, pp. 89-90).
286
Joint contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law
Report, p. 90; contribution from Ökotárs for the 2024 Rule of Law Report, p. 22.

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Funding earmarked for civil society is often absorbed by organisations affiliated with thegoverning parties287. Also in this respect, no progress has been made on the implementationof the recommendation made in the previous years to remove obstacles affecting CSOs. The
increasing lack of state funding is to some extent offset by the growing amount of individual
donations288. Cutting off CSOs from public funding increases their dependence on
crowdsourcing tools and on philanthropies and donors from abroad289.
There is little room for CSOs and human rights defenders to engage effectively withpublic institutions on issues of significant societal impact. The involvement of local
communities in debates related to investment projects (e.g. vehicle battery factories), hasbeen limited through legislation290. The Government continued the practice of ‘national
consultation’291. Independent CSOs can participate in the monitoring committees that oversee
the spending of EU funds at national level and in the Anti-Corruption Task Force292.

287

The central state support instrument to CSOs, the National Cooperation Fund provides grants annually tosome 4 000 organisations with a total budget of HUF 13.9 billion (EUR 35 151 607) in 2024. According to
the Government, the evaluation of applications and the monitoring of the attainment of the objectives
supported are carried out by five committees, each consisting of nine members, some of whom are electedby CSOs themselves. Additionally, the Village and Town Civil Funds (for CSOs operating in settlements
under and over 5 000 inhabitants, respectively) each distributed HUF 5 billion (EUR 12 644 000). A largepart of the Hungarian civil society sector is not eligible for funding by the National Cooperation Fund which
actively promotes government agendas (European Commission: Civil Society Landscape in the European
Union - Research in support of the Citizens, Equality, Rights and Values (CERV) Programme, p. 19). A
specific provision of the Public Finances Act (Section 111(9) CXCV of 2011, in fine) allows the funding
through the Town Civil Fund of CSOs that stand elections (see K-Monitor (2024), According to the State
Audit Office, the Prime Minister’s Office lawfully awards public funds to organisations that stand elections).
According to media reports, 251 (87%) of the organisations awarded at least HUF 15 million (EUR 37 933)
from the Town Civil Fund in 2021, 2022 and 2024 were affiliated with the governing party (Válasz Online(2024), Fidesz has built a gigantic network of GONGOs for the elections – several little ‘Szilárd Németh’can jump into action).
288
In 2023, both the amount collected from the assignment of 1% of personal income tax (a scheme available
since 1997) and the number of taxpayers using this option grew significantly, by approximately 26%
compared to 2022 (with a total amount HUF 15.3 billion – EUR 38 692 057 – offered by 1.8 million
taxpayers). At the same time, tax incentives for donations remain meagre: there are no tax benefits at all for
private persons after their donations, and companies may decrease their corporate tax base with 20% of the
donation, but only in case of CSOs with public benefit status (21% of all organisations) (joint contribution
from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law Report, p. 90).
289
In 2023, important new opportunities opened thanks to the EU’s Citizens, Equality, Rights and Values(CERV) program and USAID’s Central Europe program (joint contribution from Amnesty International
Hungary and eight other CSOs for the 2024 Rule of Law Report, p. 90; contribution from Ökotárs for the2024 Rule of Law Report, p. 22).
290
Between April and December 2023, an emergency measure (Government Decree 146/2023 of 27 April 2023)
allowed that townhall meetings discussing local matters be held solely via electronic means ofcommunication. Also, on 23 May 2024, the European Commission decided to open an infringement
procedure by sending a letter of formal notice to Hungary (INFR(2024)2011) for failing to fully implement
the requirements of the Convention on access to information, public participation in decision-making andaccess to justice in environmental matters (Aarhus Convention). According to the European Commission, in
its national legislation, Hungary does not ensure the right to challenge before a court all decisions oromissions of national authorities in the following environmental policy areas: nature protection, water
management, air quality, waste management, industrial emissions, and noise protection.
291
The ‘national consultation’ is a tool consisting of letters sent directly to every Hungarian household ‘onbehalf of the Government of Hungary’, accompanied by questionnaires allowing the citizens to submit
answers to sets of questions formulated by the Government and supported by a countrywide billboard and39

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Annex I: List of sources in alphabetical order** The list of contributions received in the context of the consultation for the 2024 Rule of Law report
can be found at https://commission.europa.eu/publications/2024-rule-law-report-targetedstakeholder-consultation_en
24.hu (2024), Ministerial fortunes may remain invisible as a result of a government decision(Miniszteri vagyonok maradhatnak láthatatlanok egy kormányhatározatnak köszönhetően) (15January 2024), https://24.hu/belfold/2024/01/15/miniszteri-vagyonok-kormanyhatarozat-bizalmivagyonkezelok/.
24.hu (2024), The prosecution service would send to prison Mihály Varga’s former deputy statesecretary and László Palkovics’ confidant (Varga Mihály volt helyettes államtitkárát és Palkovics
László
bizalmasátisbörtönbezárnáazügyészség)(9April2024),
https://24.hu/kozelet/2024/04/09/varga-mihaly-penzugyminiszterium-volt-helyettes-allamtitkarkarsai-tamas-palkovics-laszlo-barta-eke-gyula-korrupcio-eu-palyazat-kenopenz-vesztegetes-bortonvadirat/.
Amnesty International Hungary, Eötvös Károly Institute, Hungarian Civil Liberties Union, Hungarian
Helsinki Committee, K-Monitor, Mérték Media Monitor, Ökotárs, Political Capital, Transparency
International Hungary (2024), Joint contribution for the 2024 Rule of Law Report.
Anti-Corruption Task Force (2023), 2022 Report of the Anti-Corruption Task Forcehttps://kemcs.hu/wp-content/uploads/2023/06/Korrupcioellenes-Munkacsoport-2022-evre-vonatkozojelentese.pdf.
Anti-Corruption Task Force (2023), Complementary Report on the draft medium-term National AntiCorruption
Strategyfor2023-2025
https://kemcs.hu/wpcontent/uploads/2023/06/Kiegeszito_jelentes_NKS.pdf.
Átlátszó (2020), Corruption info: hundreds of millions of euros in EU funding for the company of theson of the minister responsible for the Paks investment (Korrupcióinfó: több százmilliós uniós
támogatás a paksi beruházásért felelős miniszter fia cégének) (23 April 2020),
https://atlatszo.hu/kozugy/2020/04/23/korrupcioinfo-tobb-szazmillios-unios-tamogatas-a-paksiberuhazasert-felelos-miniszter-fia-cegenek/.
Átlátszó (2023), We identified the companies that have won hundreds of public contracts in a single
city (16 February 2023), https://english.atlatszo.hu/2023/02/16/we-identified-the-companies-thathave-won-hundreds-of-public-contracts-in-a-single-city/.
Átlátszó (2024), Átlátszó, K-Monitor and Transparency have not accepted the annual report of theAnti-Corruption Working Group (18 March 2024), https://english.atlatszo.hu/2024/03/18/atlatszo-kmonitor-and-transparency-have-not-accepted-the-annual-report-of-the-anti-corruption-workinggroup/.
Bertelsmann Stiftung (2024), Transformation Index: Hungary Country Report https://btiproject.org/en/reports/country-report/HUN?cHash=16802a21c33eab84edaf76f4d2c323fe.

media campaign. The ‘national consultation’ organised between November 2023 and January 2024, focusedon the presumed impact of various EU policies on Hungary’s national sovereignty.
292
Joint contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law
Report, p. 92. According to stakeholders, the application of Háttér Society (an LGBTIQ organisation) toparticipate in a monitoring committee was arbitrarily rejected (contribution from Háttér Society for the 2024
Rule of Law Report, p. 12; contribution from ILGA-Europe for the 2024 Rule of Law Report, p. 29).
According to the Government, any CSOs can present their own views in the process of public consultation
on draft laws.

40

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Bloomberg (2024), Hungary Clamps Down on Orban’s Opponents with Hefty Fine (20 February2024)
https://www.bloomberg.com/news/articles/2024-02-20/opposition-deprived-of-funding-asorban-clamps-down-with-hefty-fine.
Budapest Institute (2022), Open letter announcing withdrawal from participation in the activities oftheIntegrity
Authority’s
Anti-Corruption
Task
Force
(19
May
2022),
https://www.budapestinstitute.eu/uploads/IH_MCS_level_2023.pdf.
Centre for Media Pluralism and Media Freedom (2023), Monitoring Media Pluralism in the Digital
Era in the year 2022, Country report: Hungary.
Civicus, Monitor tracking civic space – Hungary https://monitor.civicus.org/country/hungary/.
Corruption Research Center Budapest (2023), White Elephants in Hungary – Lessons of some EU
fundedprojects(29
January2023),
https://www.crcb.eu/wpcontent/uploads/2023/01/2023_research_notes_01_230129_01.pdf.
Corruption Research Center Budapest (2023), Fourteen Graphs and Two Tables on the New Trends ofCorruption Risk in the Hungarian Public Procurement 2005-2022 (7 February 2023),
https://www.crcb.eu/wpcontent/uploads/2023/02/2023_crcb_statistical_quick_report_230207_01.pdf.
Corruption Research Center Budapest (2023), The new trends of corruption risks in Hungarian public
procurement (17 October 2023), https://www.crcb.eu/?p=3450.
Corruption Research Center Budapest (2024), Two Communication Companies in the Hungarian
Public Procurement Market 2012-2023 (19 February 2024), http://www.crcb.eu/wpcontent/uploads/2024/02/2024_research_notes_01_190224_03.pdf.
Council of Bars and Law Societies of Europe (2024), Contribution from Council of Bars and Law
Societies of Europe for the 2024 Rule of Law Report.
Council of Europe: Commissioner for Human Rights (2023), Hungary: The proposal for a ‘defence ofnational
sovereignty’
packageshouldbeabandoned(27
November2023)
https://www.coe.int/ca/web/commissioner/-/hungary-the-proposal-for-a-defence-of-nationalsovereignty-package-should-be-abandoned.
Council of Europe (2023), Hungary: anti-corruption group calls for measures to prevent corruption
in central government and law enforcement (9 June 2023) https://www.coe.int/en/web/portal//hungary-anti-corruption-group-calls-for-measures-to-prevent-corruption-in-central-government-andlaw-enforcement.
Council of Europe (2024), Supervision of the execution of judgments decisions of the European Courtof Human Rights – 17th Annual Report of the Committee of Ministers – 2023
https://edoc.coe.int/en/module/ec_addformat/download?cle=a73d18446f20a30be28c26ab513da8d8&
k=af860e1889bc86177636bda12d13da47.
Council of Europe, Platform to promote the protection of journalism and safety of journalists –Hungary, https://fom.coe.int/en/pays/detail/11709524.
Court of Justice of the European Union, judgment of 16 November 2021 WB and others, C-748/19
and others, ECLI:EU:C:2021:931.
Court of Justice of the European Union, judgment of 18 June 2020, Commission v Hungary(Transparency of associations), C-78/18, ECLI:EU:C:2020:476.
Court of Justice of the European Union, judgment of 16 November 2021, Commission v Hungary(Incrimination de l’aide aux demandeurs d’asile), C-821/19), ECLI:EU:C:2021:930.
Court of Justice of the European Union, judgment of 11 January 2024, Global Ink Trade Kft., C537/22, ECLI:EU:C:2024:6.

41

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Democracy Reporting International (2024), Contribution from Democracy Reporting International forthe 2024 Rule of Law Report.
Eötvös Károly Policy Institute (2024), Contribution from Eötvös Károly Policy Institute for the 2024
Rule of Law Report.
European Anti-Fraud Office (OLAF) (2024), Annual
fraud.ec.europa.eu/about-us/reports/annual-olaf-reports_en.

Report2023

https://anti-

European Association of Judges (2024), Contribution from European Association of Judges for the2024 Rule of Law Report.
European Association of Judges (2024), Resolution on Judicial Remuneration in Hungary
https://www.iaj-uim.org/iuw/wp-content/uploads/2024/04/EAJ-Resolution-Hungary.pdf.
European Commission (2022), 2022 EU Justice Scoreboard.
European Commission (2022), 2022 Rule of Law Report, Country Chapter on the rule of law situationin Hungary.
European Commission (2023), HICP all-items — annual average inflation rates, 2013-2022
https://ec.europa.eu/eurostat/statistics-explained/index.php?title=File:HICP_allitems_%E2%80%94_annual_average_inflation_rates,_2013-2022(%25).png.
European Commission (2023), 2023 Rule of Law Report, Country Chapter on the rule of law situationin Hungary.
European Commission (2023), Civil Society Landscape in the European Union - Research in supportoftheCitizens,
Equality,
RightsandValues(CERV)
Programme
https://op.europa.eu/en/publicationdetail/-/publication/5eb1a213-c14f-11ed-891201aa75ed71a1/language-en
https://op.europa.eu/en/publicationdetail/-/publication/5eb1a213-c14f11ed-8912-01aa75ed71a1/language-en.
European Commission (2023), Commission Decision of 13 December 2023 on the reassessment, on
the Commission’s initiative, of the fulfilment of the conditions under Article 4 of Regulation (EU,
Euratom) 2020/2092 following Council Implementing Decision (EU) 2022/2506 of 15 December 2022
regardingHungary
https://commission.europa.eu/document/83f08b3a-bf4a-4462-a36188d44692452b_en.
European Commission (2024), 2024 EU Justice Scoreboard.
European Commission (2024), Economic forecast for Hungary, last update (15/02/2024), Winter2024 Economic Forecast: A delayed rebound in growth amid faster easing of inflation
https://economy-finance.ec.europa.eu/economic-surveillance-eu-economies/hungary/economicforecast-hungary_enhttps://economy-finance.ec.europa.eu/economic-surveillance-eueconomies/hungary/economic-forecast-hungary_en.
European Commission (2024), The Single Market and Competitiveness Scoreboard, Country Report:
Hungary, https://single-market-scoreboard.ec.europa.eu/countries/hungary_en.
European Commission (2024), 2024 Country Report Hungary, SWD(2024) 617 final.
European Court of Human Rights, judgment of 27 February 1980, Deweer v Belgium, 6903/75.
European Court of Human Rights, judgment of 9 November 2004, Marpa Zeeland B.V and Metal
Welding B.V. v Netherlands, 46300/99.
European Court of Human Rights, judgment of 7 October 2008, Patyi and Others v Hungary,
5529/05.
European Court of Human Rights, judgment of 26 May 2009, Kenedi v Hungary, 31475/05.
European Court of Human Rights, judgment of 16 July 2015, Gazsó v Hungary, 48322/12.

42www.parlament.gv.at

European Court of Human Rights, judgment of 12 January 2016, Szabó and Vissy v Hungary,
37138/14.
European Court of Human Rights, judgment of 23 June 2016, Baka v Hungary, 20261/12.
European Court of Human Rights, judgment of 8 November 2016, Magyar Helsinki Bizottság v
Hungary, 18030/11.
European Court of Human Rights, decision of 19 June 2018, Mendrei v. Hungary, 54927/15.
European Court of Human Rights, decision of 12 March 2019, Szalontay v Hungary, 71327/13.
European Court of Human Rights, decision of 4 June 2019, Karsai v Hungary, 22172/14.
European Court of Human Rights, judgment of 29 September 2022, Hüttl v Hungary, 58032/16.
European Implementation Network (2024), Contribution from the European Implementation Network
for the 2024 Rule of Law Report.
European Parliament: Flash Eurobarometer: News & Media Survey 2023.
Forbes (2024), Here is another 25 billion forint government corruption scandal: dozens of Mihály
Varga’s former subordinates are involved (Itt az újabb, 25 milliárdos kormányzati korrupciós
botrány: Varga Mihály tucatnyi volt beosztottja érintett) (9 April 2024), https://forbes.hu/uzlet/vargamihaly-miniszterium-korrupcio-vad-ugyeszseg/.
Friedrich Naumann Foundation and International Press Institute (2024), Watching the Watchdogs –Spyware surveillance of journalists in Europe and the ongoing fight for accountability
https://shop.freiheit.org/download/P2@1698/832928/A4%20Brosch%C3%BCre%20Watching%20the%20watchdogs_ENG_online.pdf.
GRECO (2019), Third Evaluation Round – Second Addendum to the Second Compliance Report on
Hungary on incriminations and transparency of party funding (1 August 2019)https://rm.coe.int/third-evaluation-round-second-addendum-to-the-second-compliancereport/168096947e.
GRECO (2023), Fourth Evaluation Round – Fourth Interim Compliance Report on Hungary on
corruption prevention in respect of members of parliament, judges and prosecutors (9 June 2023)
https://rm.coe.int/fourth-evaluation-round-corruption-prevention-in-respect-of-membersof/1680ab87f1.
GRECO (2023), Fifth Evaluation Round – Evaluation Report on Hungary on preventing corruption
and promoting integrity in central governments (top executive functions) and law enforcement
agencies (9 June 2023) https://rm.coe.int/fifth-evaluation-round-preventing-corruption-andpromoting-integrity-i/1680ab87f5.
Hadházy,Ákos(2024),
Facebook
postof29
January
https://www.facebook.com/hadhazyakos/posts/946406733514288?ref=embed_post.

2024

Háttér Society (2024), Contribution from Háttér Society for the 2024 Rule of Law Report.
Human Rights Watch (2024), Contribution from Human Rights Watch for the 2024 Rule of Law
Report.
Human Rights Watch (2024), ‘I Can’t Do My Job as a Journalist’ – The Systematic Undermining ofMedia Freedom in Hungary (13 February 2024) https://www.hrw.org/report/2024/02/13/i-cant-domy-job-journalist/systematic-undermining-media-freedom-hungary.
Hungarian Association of Judges (2024), Contribution from the Hungarian Association of Judges forthe 2024 Rule of Law Report.
Hungarian Civil Liberties Union (2024), Contribution from Hungarian Civil Liberties Union for the2024 Rule of Law Report.

43

www.parlament.gv.atHungarian Government (2023), The Government’s positions as regards the findings of the Integrity
Authority’s2022
annualanalytical
integrity
report(29
September2023)
https://integritashatosag.hu/wp-content/uploads/2023/10/int-hat-2022jelentes-korm-valasz.pdf.
Hungarian Government (2024), Input from Hungary for the 2024 Rule of Law Report.
Hungarian Helsinki Committee (2024), Contribution from Hungarian Helsinki Committee for the2024 Rule of Law Report.
ILGA-Europe (2024), Contribution from ILGA-Europe for the 2024 Rule of Law Report.
Integrity Authority (2023),
2022 Annual Analytical Report(29 June2023)
https://integritashatosag.hu/wpcontent/uploads/2023/06/Integritas_Hatosag_Eves_Elemzo_Integritasjelentes_20220629.pdf
https://integritashatosag.hu/wp-content/uploads/2023/10/Annual-Analytical-Integrity-Report-2022ENG.pdf.
Integrity Authority (2023), Ad-hoc report on asset declarations (7 December 2023)
https://integritashatosag.hu/wpcontent/uploads/2023/12/Integritas_Hatosag_Vagyonnyilatkozatok_Eseti_Jelentes_2023-1.pdf.
Integrity Authority (2023), The position of the Integrity Authority regarding the Government’s answer(14
December2023)
https://integritashatosag.hu/wpcontent/uploads/2023/12/Integritas_Hatosag_osszegzes_Kormanyvalaszokra_20231206.pdf.
Integrity Authority (2024), Conclusion of inquiry III_86_2023 – modernisation of cattle farm (21February 2024) https://integritashatosag.hu/case/iii_86_2023-sz-vizsgalat-lezarasa-szarvasmarhatelepkorszerusitese/.
Integrity Authority (2024), Annual Report to the Hungarian National Assembly 2023 (March 2023)
https://integritashatosag.hu/wp-content/uploads/2024/03/integrity-authority-annual-report-2023.pdf.
Intellinews (2023), Hungary’s highest-profile corruption case lifts the veil on how Orban’s regime
really operates (20 February 2023) https://www.intellinews.com/hungary-s-highest-profilecorruption-case-lifts-the-veil-on-how-orban-s-regime-really-operates-270456/.
Intellinews (2024), Hungarian State Audit Office fines opposition parties for alleged foreign
campaign finance (21 February 2024) https://www.intellinews.com/hungarian-state-audit-office-finesopposition-parties-for-alleged-foreign-campaign-financing-313363/.
International Press Institute (2024), Contribution from International Press Institute for the 2024 Ruleof Law Report.
K-Monitor (2023), Hungarian MP’s Assets: Less Declared and Still not Monitored (15 February2023) https://k.blog.hu/2023/02/15/hungarian_mp_s_assets_less_declared_and_still_not_monitored.
K-Monitor (2023), Anti-Corruption Task Force: what is the situation eight months after its launch?
(28
September2023)
https://k.blog.hu/2023/09/28/anticorruption_task_force_what_is_the_situation_eight_months_after_its_launch?utm_medium=doboz&
utm_campaign=bloghu_cimlap&utm_source=nagyvilag.
K-Monitor(2023),
ReportontheAccessto
Information(December
https://drive.google.com/drive/u/0/folders/1GwyaWR3pv2u-78gU2C8N9bfu_Qzs9yl_.

2023)

K-Monitor (2023), Anti-corruption criminal procedure reform: the rules are there, but the practice isunchanged (15 December 2023), https://k.blog.hu/2023/12/15/antikorrupcios_buntetoeljarasi_reform.
K-Monitor (2024), According to the State Audit Office, the Prime Minister’s Office lawfully awards
publicfunds
toorganisations
that
stand
elections(24March2024),
https://k.blog.hu/2024/03/25/asz_jogszeru_hogy_a_miniszterelnokseg_valasztason_indulo_szervezeteknek_oszt_kozpenzt.

44

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K-Monitor and Transparency International Hungary (2023), Letter to the European Commission,
Possible infringements of Directive 2019/1937 on the protection of persons who report breaches ofUnion law by the Hungarian Government (21 December 2023), https://transparency.hu/wpcontent/uploads/2024/01/K-Monitor_Transparency-IntHU_letter_to_COM_on_transposition_of_whistleblower_directive_21122023.pdf.
K-Monitor and Transparency International Hungary (2024), Special report on the 2023 AntiCorruption Task Force Report: Current issues in the fight against corruption in Hungary (14 March
2024),
https://transparency.hu/wpcontent/uploads/2024/03/KEMCS_2023_civil_kulonjelentes_final.pdf.
Kovács, Ágnes (2023), Taking Revenge for Dissent: Hungary’s Chief Justice to Fully Eliminate
Judicial Autonomy, VerfBlog (13 December 2023), https://verfassungsblog.de/taking-revenge-fordissent/.
Kúria (2024), Contribution from the Kúria for the 2024 Rule of Law Report.
Lakmusz (2024), How does anyone who is not a friend of Fidesz become a ‘leftist’? (5 April 2024),
https://www.lakmusz.hu/hogy-lesz-barkibol-baloldali-aki-nem-a-fidesz-baratja-2/.
Magistrats Européens pour la Démocratie et Libertés (MEDEL) (2024), Contribution from Magistrats
Européens pour la Démocratie et Libertés (MEDEL) for the 2024 Rule of Law Report.
Magyar Hang (2024), 54 people indicted in corruption case involving the Ministry of Finance and thePrime Minister’s Office (54 fő ellen emeltek vádat a Pénzügyminisztériumot és a Miniszterelnökségetérintő korrupciós ügyben) (9 April 2024), https://hang.hu/belfold/penzugyminiszterium-ugyeszsegminiszterelnokseg-vadirat-korrupcio-163101.
Mérték Media Monitor (2024), Contribution from Mérték Media Monitor for the 2024 Rule of Law
Report.
Minister of Interior (2023), Letter to the chairperson of the Anti-Corruption Task Force (16 October2023) https://kemcs.hu/wp-content/uploads/2023/10/NKS-kiegeszito-jelentesre-adott-Kormanyzatiallaspont.pdf.
National Judicial Council (2024), Verbatim minutes of the 14 February 2024 meeting of the National
Judicial Council https://obt-jud.hu/sites/default/files/ulesek/Az-OBT-2024.-februar-14-i-ulesenekjegyzokonyve.pdf.
National Judicial Council (2024), Verbatim minutes of the 27 March 2024 meeting of the National
Judicial Council https://obt-jud.hu/sites/default/files/ulesek/Jegyzokonyv_2024.03.27.pdf.
National Media and Infocommunications Authority (2023), Media Market Report 2023
https://english.nmhh.hu/article/242928/Media_Market_Report_2023.
OECD (2021), Implementing the OECD Anti-Bribery Convention, Phase 4 Two-Year Follow-Up
Report: Hungary https://www.oecd.org/daf/anti-bribery/hungary-phase-4-follow-up-report.pdf.
OECD (2023), OECD Working Group on Bribery public statement on Hungary (31 January 2023)
https://www.oecd.org/corruption/oecd-working-group-on-bribery-public-statement-on-hungary-3101-2023.htm.
OECD (2023), Implementing the OECD Anti-Bribery Convention, Phase 4 Evaluation of Hungary:
additional
writtenfollow-up
report(25
October2023)
https://one.oecd.org/document/DAF/WGB(2023)35/FINAL/en/pdf?sessionId=1700663306729.
OECD (2023), A strategic approach to public integrity in Hungary: The 2023-2025 National AntiCorruption Strategy and Action Plan (16 November 2023) https://www.oecdilibrary.org/docserver/a5461405en.pdf?expires=1710511674&id=id&accname=oid031827&checksum=A968A42BA18AE860769123
CD88C99C24.

45

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OSCE ODIHR and Venice Commission (2020), Guidelines on Political Party Regulation, Second
Edition https://www.osce.org/files/f/documents/8/1/538473.pdf.
OSCE ODIHR (2022), Hungary Parliamentary Elections and Referendum - 3 April 2022 - ODIHR
Election Observation Mission Final Report https://www.osce.org/files/f/documents/2/6/523568.pdf.
Ökotárs (2024), Contribution from Ökotárs for the 2024 Rule of Law Report.
Prosecution service (2024), Indictment in a case related to tender grants obtained through corruption– with video – press release of the Central Chief Investigating Prosecution Office, (Vádemelés akorrupció útján szerzett pályázati támogatások ügyében - videóval - a Központi NyomozóFőügyészség sajtóközleménye) (12 February 2024), https://ugyeszseg.hu/vademeles-a-korrupcioutjan-szerzett-palyazati-tamogatasok-ugyeben-videoval-a-kozponti-nyomozo-fougyeszsegsajtokozlemenye/.
Reporters Without Borders (2023), 2023 World Press Freedom Index.
Reporters Without Borders (2024), Contribution from Reporters Without Borders for the 2024 Rule of
Law Report.
Res Iudicata Association (2024), Contribution from Res Iudicata Association for the 2024 Rule of
Law Report.
Reuters (2024), In unusual move, China offers to back Hungary in security matters (20 February2024),
https://www.reuters.com/world/unusual-move-china-offers-back-hungary-security-matters2024-02-19/.
Reuters (2024), Hungary prosecutors probe graft case tape leaked by former government insider (28March 2024), https://www.reuters.com/world/europe/hungary-prosecutors-probe-graft-case-tapeleaked-by-former-government-insider-2024-03-28/.
RTL (2024), The government covers up certain corporate assets of ministers with an undisclosed
decision (Nem nyilvános határozattal fedi el a kormány a miniszterek bizonyos céges vagyonait) (15January 2024), https://rtl.hu/belfold/2024/01/15/nem-nyilvanos-hatarozat-bizalmi-vagyonkezelokormany-miniszter-ceges-erdekeltseg-vagyon.
SELDI (2023), Bridges to nowhere – State Capture and Corruption Risks in Fiscal Transfers andPublic Procurement at the Local Level in Southeast Europe https://seldi.net/wpcontent/uploads/2023/11/Bridges-to-Nowhere-2.pdf.
State Audit Office (2024), Partial Audit Report on the accounting of funds spent on the 2022
parliamentary election campaign in case of Democratic Coalition (DK), Jobbik Movement for a
Better Hungary, Momentum Movement, Hungarian Socialist Party (MSZP), LMP-Hungary’s Green
Party, Dialogue for Hungary (Részjelentés - Kampánypénzek ellenőrzése - A 2022. évi országgyűlési
képviselő-választási kampányra fordított pénzeszközök elszámolásának ellenőrzése hat jelölő.
szervezetnél), https://www.asz.hu/dokumentumok/23025.pdf.
Szabad Európa (2024), Overpricing is only one of the tricks – this is how Gyula Balásy gets all stateorders (A túlárazás csak az egyik trükk – így tarol Balásy Gyula az állami megrendeléseken) (7March2024),
https://www.szabadeuropa.hu/a/rogan-balasy-gyula-lounge-new-landtularazas/32843686.html.
Telex (2023), There are already 34 suspects in the bribery case involving the Ministry of Finance and
the Prime Minister’s Office (Már 34 gyanúsítottja van a Pénzügyminisztériumot és a
Miniszterelnökségetisérintő
vesztegetésiügynek)(3March2023),
https://telex.hu/belfold/2023/03/03/vesztegetes-miniszterelnokseg-ugyeszseg-palyazatpenzugyminiszterium-korrupcio-buncselekmeny-nyomozas.
Telex (2024), SAO: CÖF and Megafon said that they had not cooperated with Fidesz (ÁSZ: A CÖF
és a Megafon azt mondták, hogy ők nem működtek együtt a Fidesszel) (20 February 2024)
https://telex.hu/belfold/2024/02/20/asz-kampanytamogatas-mmm-megafon-cof.

46

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Telex (2024), The Integrity Authority filed a complaint over the half-billion forint ‘dairy farm’ of thefamily of ex-minister János Süli (Az Integritás Hatóság feljelentést tett Süli János exminiszter
családjának
félmilliárdos
„tehenészete”
miatt)(21
February2024)
https://telex.hu/gazdasag/2024/02/21/hatosagi-feljelentes-suli-janos-exminiszter-csaladjanakfelmilliardos-teheneszete-miatt.
Telex (2024), Former Justice Minister’s ex-husband releases recording he claims proof of high-level
involvement in corruption case (26 March 2024), https://telex.hu/english/2024/03/26/damningrecording-about-orbans-right-hand-man-trying-to-cover-up-involvement-in-corruption-published-byformer-justice-ministers-ex-husband.
Telex (2024), The Sovereignty Protection Office has no problem with Chinese policemen coming to
Hungary (A Szuverenitásvédelmi Hivatal szerint semmi baj nincs azzal, hogy kínai rendőrök jönnek
Magyarországra) (3 April 2024), https://telex.hu/belfold/2024/04/03/szuveneritasvedelmi-hivatal-dkkinai-rendorok.
Telex (2024), Transparency International and Átlátszó became the first targets of the Sovereignty
Protection Office (A Transparency International és az Átlátszó lettek a Szuverenitásvédelmi Hivatalelső célpontjai) (25 June 2024), https://telex.hu/belfold/2024/06/25/szuverenitasvedelmi-hivataltransparency-international-vizsgalat-indul.
The Budapest Times (2023), Prosecutors investigate a further 9 people in EU tenders bribery case (3March 2023), https://www.budapesttimes.hu/hungary/prosecutors-investigate-a-further-9-people-ineu-tenders-bribery-case/.
The Budapest Times (2024), KNYF: ‘No documents disappeared in so-called Volner-Schadl case’ (28March 2024), https://www.budapesttimes.hu/hungary/knyf-no-documents-disappeared-in-so-calledvolner-schadl-case/.
Transparency
International(2022),
ExportingCorruption
https://images.transparencycdn.org/images/2022_Report-Full_Exporting-Corruption_English.pdf.
Transparency International Hungary (2024), Contribution from Transparency International Hungary
for the 2024 Rule of Law Report.
Transparency International Hungary (2024), Press statement: Hungary’s Sovereignty Protection
Office targets Transparency International Hungary with investigation (25 June 2024)
https://transparency.hu/en/news/spo-targets-ti-hungary/.
UN Human Rights Regional Office for Europe (2024), Contribution from UN Human Rights Regional
Office for Europe for the 2024 Rule of Law Report.
UN Office of the High Commissioner for Human Rights (2023), Mandates of the Special Rapporteuron the promotion and protection of the right to freedom of opinion and expression and the Special
Rapporteur on the situation of human rights defenders (8 December 2023),
https://spcommreports.ohchr.org/TMResultsBase/DownLoadPublicCommunicationFile?gId=28661.
Válasz Online (2024), Fidesz has built a gigantic network of GONGOs for the elections – several
little ‘Szilárd Németh’ can jump into action (A Fidesz gigantikus álcivil hálózatot épített aválasztásokra – sok kis „Németh Szilárd” léphet akcióba) (22 January 2024),
https://www.valaszonline.hu/2024/01/22/fidesz-varosi-civil-alap-nemethszilard-valasztasok/.
Venice Commission (2012), Opinion on Act CLI of 2011 on the Constitutional Court of Hungary(CDL-AD(2012)009).
Venice Commission (2024), Opinion on the Act LXXXVIII of 2023 on the Protection of National
Sovereignty (CDL(2024)002).
Die Welt (2024), When the Chinese police can lawfully patrol in the EU (Wenn die chinesische
Polizei
legal
in
der
EU
patrouilliert)
(15
March
2024),

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Annex II: Country visit to Hungary
The Commission services held virtual meetings in February 2024 with:
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x

Amnesty International HungaryÁtlátszó
Bea Bodrogi lawyer, media expert
Buda Central District Court
Corruption Research Center Budapest
ELTE Media Department
Eötvös Károly Policy Institute
Hungarian Association of Journalists (MÚOSZ)Hungarian Association of Judges (MABIE)
Hungarian Bar Association (MÜK)
Hungarian Civil Liberties Union (TASZ)
Hungarian Chamber of Commerce and Industry (MKIK)
Hungarian Helsinki Committee
Integrity Authority
K-Monitor
Kúria (Supreme Court)
Media Service Support and Asset Management Fund (MTVA)
Mérték Media Monitor
Ministry for European Affairs
Ministry of Finance
Ministry of Interior
Ministry of JusticeNational Assembly (Országgyűlés)National Data Protection and Freedom of Information Authority (NAIH)
National Judicial Council (OBT)
National Media and Infocommunications Authority (NMHH)
National Office for the Judiciary (OBH)
Office of the Commissioner for Fundamental Rights
Prosecution Service of Hungary
State Audit Office (Állami Számvevőszék)
Transparency International Hungary* The Commission also met the following organisations in a number of horizontal meetings:
x
x
x
x
x

Amnesty International EU
Centre for Democracy and Technology Europe
Centre for European Volunteering
Civil Liberties Union for Europe
Civil Rights Defenders

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x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x

Civil Society Europe
Culture Action Europe
Democracy Reporting International
European Centre for Non-Profit Law
European Civic Forum
European Federation of Journalists
European Partnership for Democracy
European Youth Forum
Free Press Unlimited
International Federation for Human Rights
International Planned Parenthood Federation
International Press Institute
Irish Council for Civil Liberties
JEF Europe
Open Society Foundations
Philanthropy Europe Association
PICUM
Reporters Without Borders
SOLIDAR
Transparency International EU

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